Myers and Others v. Anderson; Same v. Howard; Same v. Brown

Background

Three Black men applied to be registered to vote in Annapolis under a 1908 Maryland law and were refused registration by local officers. The law set three categories for who could register: a property qualification, naturalized citizens (and their male descendants), and a clause allowing only those entitled to vote before January 1, 1868 (and their male descendants). The men sued the registration officers for damages under a federal statute, saying they were deprived of voting rights guaranteed by the Fifteenth Amendment.

Reasoning

The core question was whether the statute’s categories violated the Fifteenth Amendment’s ban on racial discrimination in voting. The Court found the third category — the ‘‘pre‑1868 voters and descendants’’ clause — to be identical in effect to a clause already held invalid and therefore repugnant to the Fifteenth Amendment. The opinion assumed, for argument’s sake, that the property and naturalization categories were valid, but explained that the invalid third clause so dominated the statute and produced absurd results if left standing that the officers’ refusals could not be justified. The Court therefore affirmed the judgments for the plaintiffs and allowed recovery under the federal statute.

Real world impact

The decision makes clear that laws attempting to restore pre‑Civil War voting exclusions by ancestry or grandfather rules are unlawful. Local election officials cannot rely on such clauses to deny registration, and harmed individuals may sue for damages under federal law. Justice McReynolds did not participate in these cases.