Mason v. Missouri

Background

In Missouri, the legislature had earlier passed a voter-registration law for cities with over 100,000 people. Later, the Nesbit law of June 19, 1899 applied new registration rules to cities with more than 300,000 people, which included St. Louis. A public official responsible for running elections challenged the change. He argued that taking St. Louis out of the earlier 1895 law and subjecting it to the Nesbit law treated St. Louis voters differently and denied them equal protection under the Fourteenth Amendment.

Reasoning

The Court reviewed how the state constitution allowed the legislature to create classes of cities by population. The Missouri Supreme Court had decided that the constitution did not forbid making more than one class of cities above 100,000 inhabitants. Because the state court found the Nesbit law consistent with the state constitution, this Court accepted that conclusion. The opinion explained that the right to vote is granted and regulated by the State. The difference between the older 1895 law and the Nesbit law does not automatically show unconstitutional discrimination. The federal Fourteenth Amendment was not violated simply because a state legislature chose different registration rules for different city-size classes.

Real world impact

The decision leaves Missouri’s city classification and voter-registration choices in the hands of state lawmakers and courts. St. Louis voters must follow the registration law that the state applies to their city size. The ruling affirms that differences in state voting rules, if consistent with the state constitution, do not by themselves trigger federal equal protection problems.