Leser v. Garnett
Headline: Confirms women's right to vote by upholding the Nineteenth Amendment and allowing women registered to vote despite Maryland's refusal to ratify, making state refusals to ratify ineffective.
Holding: The Court held that the Nineteenth Amendment had become part of the Federal Constitution and that women lawfully registered may vote despite Maryland’s refusal to ratify.
- Women registered in Maryland must be allowed to vote despite state refusal to ratify.
- State constitutional or procedural rules cannot block a validly certified federal amendment.
- Secretary of State’s certification that an amendment is ratified is binding on courts.
Summary
Background
On October 12, 1920, two women in Baltimore applied for and were granted registration as qualified voters. Local voters sued to have their names removed because Maryland’s constitution then limited voting to men. The Nineteenth Amendment — giving women the vote — had been proclaimed ratified on August 26, 1920, even though Maryland’s legislature refused to ratify it. Lower courts rejected the challenge and the case reached the national court for review.
Reasoning
The key question was whether the Nineteenth Amendment had truly become part of the Federal Constitution so it could override a state rule limiting voting to men. The Court said the Amendment is in the same form and adopted the same way as the Fifteenth Amendment, which had long been treated as valid. It also explained that when state legislatures act to ratify a federal amendment they are performing a federal function that state rules or state constitutional limits cannot block. Finally, the Court relied on the Secretary of State’s official certification that thirty-six states had ratified; that official certification is conclusive and must be accepted by the courts.
Real world impact
The decision means the national amendment giving women the vote is effective even in states that declined to ratify. Women lawfully registered under the amendment must be allowed to vote, and state constitutional provisions or procedural objections cannot prevent a validly certified federal amendment from taking effect.
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