Myers v. Anderson

Background

Three Black men in Annapolis applied to be registered to vote under a 1908 Maryland municipal law and were denied registration by the local board. The law set three classes of voters: a property-based class, naturalized citizens and their descendants, and a third class limited to people (or their lawful male descendants) who, before January 1, 1868, were entitled to vote. The men sued the registering officers for damages, arguing the refusal violated the Fifteenth Amendment and seeking relief under the federal civil-rights statute (§1979, Rev. Stat.).

Reasoning

The core question was whether the statute’s voter qualifications violated the Fifteenth Amendment’s ban on racial voting discrimination. The Court held the third “grandfather” standard was void because it effectively re-created the racial exclusion the Amendment forbids. Although the Court treated the property and naturalization standards as valid or assumed them so for argument’s sake, it concluded the provision as a whole tied those clauses to the illegal third clause. That unity meant striking down the third clause defeated the statute’s operation. The Court also emphasized that federal constitutional protections are self-operative and that state changes to registration procedures do not shield officials from federal law. The judgments for the plaintiffs were affirmed.

Real world impact

The ruling removes a device that allowed states to restore racial voting exclusions through registration laws. It confirms that individuals denied registration because of such a clause can sue under the federal civil-rights statute. It also makes clear local election officials cannot evade the Fifteenth Amendment by relying on state registration formulas.