ANDERSON Et Al. v. MARTIN
1964 U.S. LEXIS 1990, 11 L. Ed. 2d 430, 375 U.S. 399 (1964)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A state statute requiring the designation of a candidate's race on election ballots is unconstitutional because it places the state's power behind a racial classification that induces and encourages voters to discriminate on the basis of race, violating the Equal Protection Clause of the Fourteenth Amendment.
Facts:
- In 1960, Louisiana enacted a statute requiring that every candidate's race be printed in parentheses next to their name on all primary, general, and special election ballots.
- Prior to this 1960 law, ballots in Louisiana contained only the candidate's name and, in general elections, their political party.
- Appellants Anderson and Belton, both Negroes, were residents of East Baton Rouge, Louisiana.
- In 1962, Anderson and Belton ran as candidates for the East Baton Rouge Parish School Board in the Democratic Party primary election.
- Pursuant to the 1960 statute, the state-printed ballots designated the race of both Anderson and Belton.
- Both appellants were defeated in the election.
Procedural Posture:
- The appellants, two Negro candidates, sued the Louisiana Secretary of State in a three-judge United States District Court.
- The suit sought to enjoin the enforcement of the state statute requiring racial designation on ballots.
- The District Court denied the appellants' request for a preliminary injunction, with one judge dissenting.
- The appellants' later motion to amend their complaint after losing the election was denied.
- The three-judge District Court then denied the request for a permanent injunction, upholding the statute as constitutional.
- The appellants filed a direct appeal to the Supreme Court of the United States, which noted probable jurisdiction.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a state law requiring that the race of every candidate for elective office be designated on the ballot violate the Equal Protection Clause of the Fourteenth Amendment?
Opinions:
Majority - Mr. Justice Clark
Yes, the state law violates the Equal Protection Clause. By placing a racial label on a candidate at the most crucial stage of the electoral process, the state provides a vehicle for racial prejudice to influence the vote. The statute directs the voter's attention to race as a paramount consideration, thereby placing the power of the state behind a racial classification that induces racial prejudice at the polls. The state's argument that the law is non-discriminatory because it applies to all races is superficial; that which cannot be done by direct statutory prohibition, such as barring candidates based on race, cannot be done by indirection. The court found no relevance in a candidate's race as it bears upon their qualifications for office, concluding that the classification's sole purpose was to promote racial discrimination.
Analysis:
This decision extends the application of the Equal Protection Clause to the mechanics of the electoral process, specifically the content of the ballot. It establishes the important precedent that facially neutral state actions that classify individuals by race are unconstitutional if their purpose and effect are to encourage private discrimination. The ruling prevents states from using the ballot itself as an instrument to inject racial considerations into voting, reinforcing the principle that states cannot indirectly achieve what the Constitution forbids them from doing directly.
