Leser v. Garnett
258 U.S. 130, 1922 U.S. LEXIS 2250, 42 S. Ct. 217 (1922)
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Rule of Law:
The ratification of a federal constitutional amendment is a federal function that transcends any limitations imposed by a state's constitution, and the official certification of its adoption by the Secretary of State is conclusive upon the courts.
Facts:
- The constitution of Maryland limited suffrage to men.
- The Nineteenth Amendment to the U.S. Constitution was proclaimed as ratified on August 26, 1920, prohibiting the denial of the right to vote based on sex.
- The Legislature of Maryland had refused to ratify the Nineteenth Amendment.
- On October 12, 1920, Cecilia Streett Waters and Mary D. Randolph, two women who were citizens of Maryland, were granted registration as qualified voters in Baltimore City.
- Oscar Leser and other citizens challenged the registration of Waters and Randolph, alleging their only disqualification was that they were women.
Procedural Posture:
- Oscar Leser and others filed a suit in the Court of Common Pleas of Baltimore City (a state trial court) to strike the names of two women from the list of registered voters.
- The trial court dismissed the petition, upholding the women's registration.
- Leser, as appellant, appealed the dismissal to the Court of Appeals of Maryland (the state's highest court).
- The Court of Appeals of Maryland affirmed the judgment of the trial court.
- Leser, as petitioner, was granted a writ of certiorari by the Supreme Court of the United States to review the case.
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Issue:
Has the Nineteenth Amendment, providing for women's suffrage, become a valid part of the Federal Constitution despite claims that its character destroys state autonomy and that there were procedural irregularities in the ratification process by several states?
Opinions:
Majority - Mr. Justice Brandeis
Yes. The Nineteenth Amendment has become a valid part of the Federal Constitution. First, the petitioners' argument that the amendment's character destroys state autonomy fails because the Nineteenth Amendment is identical in character to the Fifteenth Amendment, which has been recognized as valid for half a century and cannot be distinguished. Second, the argument that certain state legislatures were unable to ratify due to limitations in their own state constitutions is incorrect; the function of a state legislature in ratifying a proposed federal amendment is a federal function derived from the U.S. Constitution and therefore transcends any limitations imposed by state law. Finally, claims of procedural irregularities in the ratifications of Tennessee and West Virginia are immaterial because the official, authenticated notice to the Secretary of State that a legislature has ratified an amendment is conclusive upon him, and his subsequent proclamation is conclusive upon the courts.
Analysis:
This decision firmly established the validity of the Nineteenth Amendment and, more broadly, reinforced the supremacy of the federal constitutional amendment process outlined in Article V. By declaring that ratification is a 'federal function,' the Court prevented states from using their own constitutions to block federal amendments. Furthermore, by treating the Secretary of State's proclamation of ratification as conclusive, the Court effectively made challenges to the internal legislative procedures of ratification a non-justiciable political question, thereby ensuring finality and stability in the constitutional amendment process.
