Guinn v. United States

Background

This dispute arose after Oklahoma adopted a suffrage amendment before a 1910 election. Local election officers refused to let certain Black citizens vote. Those citizens said they were qualified under the State’s original constitution but excluded under the new amendment, which required reading and writing except for people entitled to vote on January 1, 1866, or their descendants. Federal prosecutors charged the officers with conspiring to deprive those citizens of their Fifteenth Amendment right to vote.

Reasoning

The Court focused on whether the 1866-based exemption conflicted with the Fifteenth Amendment, which forbids denying the vote because of race. The Court concluded that basing eligibility on a pre-1866 date effectively revived conditions the Fifteenth Amendment outlawed, so that part of the amendment was void. The Court also explained that a general literacy test is an exercise of state power over voting and, standing alone, is lawful. Because the text of the amendment clearly exempted the 1866 class from the literacy test, the invalid 1866 provision could not be used to nullify the literacy rule generally.

Real world impact

The ruling prevents Oklahoma from using the 1866 date to deny voting rights on a racial basis, while allowing literacy tests to remain in force. The decision answers the constitutional questions for the ongoing criminal case, but the jury still must decide whether the officers acted with corrupt intent or in honest mistake under the trial instructions.

Dissents or concurrances

One Justice (McReynolds) took no part in the case.