Katzenbach v. Morgan

Background

A group of registered New York City voters challenged a provision of the Voting Rights Act that protects people who completed at least six grades in American-flag schools where the main classroom language was not English—chiefly Puerto Rican schools. New York required voters to show ability to read and write English, which had kept many Puerto Rican migrants from voting. A three-judge federal trial court held the federal provision invalid, and the case reached the Supreme Court on direct appeal.

Reasoning

The Court asked whether Congress, using its power to enforce the Fourteenth Amendment, could bar a State from enforcing an English literacy voting rule for people educated in those non-English American-flag schools. Applying a broad test from earlier cases, the majority concluded that Congress reasonably found the law would secure equal treatment for that Puerto Rican community and that the measure was an appropriate means to enforce the Equal Protection guarantee. Because federal law controls where it conflicts with state law, the Court held New York’s literacy rule cannot be enforced to the extent it conflicts with the federal provision.

Real world impact

The ruling prevents New York from using its English literacy requirement to disqualify many citizens educated in Puerto Rican schools and is intended to enlarge their political power. The Court said that gaining the vote should help that community obtain fairer treatment in public services like schools, housing, and policing. The majority treated Congress’ judgment about these practical effects as within its enforcement authority under the Fourteenth Amendment.

Dissents or concurrances

A dissenting opinion argued the decision upsets the balance between courts and Congress and between federal and state authority. The dissent would have upheld New York’s literacy test and rejected Congress’ power to override that state voting rule without the kind of judicially reviewable record the dissent favored.