Gaston County v. United States
Headline: Court affirmed denial of Gaston County’s request to reinstate a literacy voting test, finding segregated, inferior Black schools made the test discriminatory and barred the county from restoring it.
Holding: The Court held that Gaston County failed to prove its literacy voting test did not discriminatorily deny Black citizens the franchise because the county’s history of separate, inferior schools prevented reinstatement.
- Blocks reinstatement of literacy tests where past segregation left Black citizens educationally disadvantaged.
- Requires jurisdictions to prove tests lack discriminatory effect despite historic inequalities.
- Protects older Black residents harmed by past unequal schooling from new literacy barriers.
Summary
Background
Gaston County, North Carolina sought to restart a state literacy test for voter registration after the Voting Rights Act suspended its use. The United States sued to prevent reinstatement, arguing the County’s long history of separate and unequal schools left many Black residents educationally disadvantaged and unable to meet the test.
Reasoning
The central question was whether the County could prove the literacy test did not have a discriminatory effect given its record of segregated schools. The Court relied on the Act’s legislative history and extensive trial evidence — low Black teacher pay, far fewer Black teachers with full certification, lower per-pupil school values for Black schools, and higher illiteracy among Black adults — to conclude the Government made a strong showing that the test discriminated. The County’s lone rebuttal witness was found unpersuasive, and the Court held the County failed to meet its burden to prove no discriminatory effect.
Real world impact
The ruling bars Gaston County from reinstating the literacy requirement and affirms that courts may consider a locality’s history of segregated, inferior schools when judging whether a voting test discriminates. The decision protects older Black residents harmed by past schooling inequalities, and it requires governments to show tests do not perpetuate those harms before restoring them.
Dissents or concurrances
Justice Black dissented for reasons similar to his prior separate opinion in a related Voting Rights Act case, disagreeing with the majority’s approach to the Act’s enforcement.
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