Hadnott v. Amos
Headline: Court reverses Alabama exclusion of mostly Black NDPA candidates, seats winners in three counties and orders a new Greene County election due to discriminatory enforcement and Voting Rights Act issues.
Holding: The Court held that Alabama officials unlawfully excluded mostly Black NDPA candidates by applying filing rules unequally and that the Garrett Act required federal preclearance under the Voting Rights Act, so relief was ordered.
- Requires NDPA candidates to appear on ballots and orders a new Greene County election.
- Prevents enforcing Alabama’s new filing deadline without federal Voting Rights Act approval.
- Reinforces protection against racially unequal application of election rules.
Summary
Background
The National Democratic Party of Alabama (NDPA), which ran mostly Black candidates, sued Alabama officials after many NDPA names were left off local ballots in 1968. A three-judge federal court dissolved a temporary order protecting the NDPA, but this Court restored temporary relief, heard the case, and considered why some NDPA candidates were excluded. In Greene County, where Black voters were a numerical majority, NDPA candidates were omitted from the regular ballot and might have won if listed.
Reasoning
The Court addressed whether state filing rules were applied fairly and whether a new Alabama filing law needed federal approval before being used. The Justices found that the Corrupt Practices form filings made by the NDPA candidates in February reasonably covered nomination and election and that officials gave no adequate reason for treating Black candidates differently. The Court also decided that the 1967 Garrett Act, which changed filing deadlines and party-declaration rules, imposed new burdens on independent or new-party candidates and therefore required federal preclearance under the Voting Rights Act before being enforced.
Real world impact
Because officials applied the filing rules unequally and the Garrett Act lacked required federal approval, the Court ordered relief: the prevailing NDPA candidates in three counties must be treated as duly elected, and a new Greene County election must be held with NDPA names on the ballot. The decision protects voters from unequal treatment when election officials enforce filing rules.
Dissents or concurrances
Justice White, joined by Justice Stewart in part, would have sent the question about whether a second committee filing was required back to the lower court for a state-law interpretation before deciding the constitutional issues.
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