Lassiter v. Northampton County Board of Elections

Supreme Court of United States
360 U.S. 45 (1959)

ELI5:

Rule of Law:

A state may condition the right to vote on the ability to read and write, provided the literacy test is applied fairly to all races and is not a mechanism for unconstitutional discrimination.

Facts:

Lassiter, a Black citizen of North Carolina, applied to register as a voter.
The local registrar required Lassiter to submit to a literacy test as mandated by North Carolina statute.
The test required that a prospective voter be able to read and write any section of the Constitution of North Carolina in the English language.
Lassiter refused to take the literacy test.
As a direct result of her refusal to submit to the test, the registrar denied her application for voter registration.

Procedural Posture:

Lassiter was denied registration by the registrar for refusing to take a literacy test.
She appealed to the County Board of Elections, which held a de novo hearing and affirmed the denial of registration.
Lassiter appealed the Board's decision to the Superior Court of North Carolina, a state trial court, which sustained the Board's action.
Lassiter, as appellant, appealed the trial court's decision to the North Carolina Supreme Court, the state's highest court.
The North Carolina Supreme Court affirmed the judgment of the Superior Court.
Lassiter then appealed to the Supreme Court of the United States.

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Issue:

Does a state law requiring all prospective voters to be able to read and write a section of the state constitution in English, when applied to all races, violate the Fourteenth, Fifteenth, or Seventeenth Amendments of the U.S. Constitution?

Opinions:

Majority - Mr. Justice Douglas

No. A state law requiring that voters pass a literacy test does not, on its face, violate the Fourteenth, Fifteenth, or Seventeenth Amendments. States possess broad powers to set voter qualifications, and the ability to read and write bears a rational relationship to the state's legitimate interest in promoting the intelligent exercise of the franchise. While the right to vote is constitutionally protected, it is subject to state standards that are not discriminatory or in contravention of federal law. The Court reasoned that literacy is a neutral standard, unlike tests designed to be vague and discriminatory as seen in Davis v. Schnell. Since Lassiter did not allege that the test was applied in a discriminatory manner, but only challenged its facial validity, the requirement is a permissible exercise of state authority.

Analysis:

This decision upheld the facial constitutionality of literacy tests, reinforcing the principle of broad state authority in setting voter qualifications. By finding such tests neutral on their face, the Court placed a high burden on plaintiffs to prove discriminatory intent or application in future cases. This ruling legitimized a tool commonly used to disenfranchise minority voters, particularly in the South, and its holding was effectively superseded by the federal Voting Rights Act of 1965, which banned the use of literacy tests in voting nationwide.

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