Myers v. Anderson
The Court struck down a Maryland law that let Annapolis officials register voters based on whether they or their ancestors could have voted before 1868 — a date chosen because Black men could not vote in Maryland then. Relying on its decision the same day in Guinn v. United States, the Court held this 'grandfather clause' unconstitutional under the Fifteenth Amendment.
Because that voting standard could not be separated from the rest of the registration law, the whole scheme fell, and the Court upheld money-damage judgments against the registration officials who had turned away three Black applicants.
“the third standard is void because it amounts to a mere denial of the operative effect of the Fifteenth Amendment and, based upon that conception, proceeds to re-create and reestablish a condition which the Amendment prohibits”
The Court's core holding that the 1868 voting-date requirement was an unconstitutional grandfather clause.
How it got here: A federal circuit court overruled the officials' demurrers, tried the cases without a jury, and entered judgment for the men; the officials brought writs of error to the Supreme Court.
The Case in Depth
What happened
Annapolis, Maryland required voters to register under a 1908 law setting three qualification categories, one of which let a person register if they — or an ancestor — could have voted in Maryland before January 1, 1868. Because Black men could not vote in Maryland before the Fifteenth Amendment, this class effectively excluded Black citizens who lacked the property or naturalization qualifications in the other two categories. Three Black men who met the law's other requirements were denied registration and could not vote in a 1909 election.
The question before the Court
Could Annapolis, Maryland deny voter registration to Black citizens by requiring proof that they (or their ancestors) could have voted before January 1, 1868 — before Black men gained the right to vote?
The Court's answer
No — the Court ruled that Annapolis could not use the 1868 voting-date requirement to deny registration to Black citizens. It found this standard functionally identical to the grandfather clause struck down that same day in Guinn v. United States, because it simply revived the racial exclusion the Fifteenth Amendment had already erased, using a neutral-sounding date instead of the word "race."
Because that invalid standard could not be separated from the law's other qualifications without producing an absurd result, the whole registration scheme fell, and the pre-existing Maryland law — open to all male citizens regardless of race — controlled instead. The officials who refused to register the three Black applicants under that surviving law were therefore liable for damages.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
The ruling confirmed that voting officials who enforce a racially discriminatory registration rule can be sued for money damages, not just have the rule struck down. It extended the Court's same-day Guinn decision to municipal elections and to private lawsuits for damages, giving disenfranchised voters a concrete remedy against the officials who denied them registration.
What changes now
The judgments awarding damages against the registration officials were affirmed, finally resolving the three lawsuits. The Annapolis grandfather-clause registration scheme was rendered void as a whole, and the pre-existing statewide qualification standard (open to all male citizens regardless of race) governed Annapolis elections going forward. This was a final merits decision, not a temporary or procedural order.
What this does not decide
The Court expressly avoided deciding whether the law's property-tax and naturalized-citizen registration standards were independently constitutional, assuming for argument's sake that they were valid; its ruling rested on severability, not on approving those categories.
How the Court got there
The legal reasoning, step by step
- The Court compared Annapolis's third registration standard — tied to who could have voted before January 1, 1868 — to the nearly identical 'grandfather clause' it had just struck down that same day in Guinn v. United States, finding it repugnant to the Fifteenth Amendment because it simply re-created the racial exclusion the Amendment had already abolished.
- The Court then examined the law's other two standards (a property-tax qualification and a naturalized-citizen qualification), finding no facial racial discrimination in either and assuming, without deciding, that both were constitutionally valid on their own.
- Because eliminating only the invalid grandfather-clause standard would leave the applicants unqualified under any surviving standard, the Court had to decide whether the valid standards could survive the fall of the invalid one — a severability question resolved under a two-part test: whether the law expressly tied the standards together, or whether letting the valid ones survive alone would create so absurd a result that lawmakers could not have intended it.
- Applying that test, the Court found both conditions met: the property qualification appeared designed only to reach people not already covered by the other classes, and letting the property and naturalization standards survive alone would produce the incongruous result that native-born citizens needed property to vote while naturalized citizens and their descendants needed none.
- Because the entire new municipal registration scheme was therefore void as a unit, the Court held that the pre-existing Maryland election law — which, by the Fifteenth Amendment's self-operative force, already extended suffrage to 'every male citizen' regardless of race — continued to govern, meaning the registration officials had a duty to register the men and were liable in damages for refusing.
Doctrinal impact
Cases affected by this decision
Reaffirms Guinn Case
Applies the same day's ruling that grandfather-clause voting standards violate the Fifteenth Amendment.