United States v. James Griggs Raines et al.
362 U.S. 17, 80 S. Ct. 519, 4 L. Ed. 2d 524 (1960)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A party to whom a statute is constitutionally applied will not be heard to attack the statute on the ground that it might be unconstitutional as applied to other parties or in other hypothetical situations.
Facts:
- James Griggs Raines and other defendants served as members of the Board of Registrars and Deputy Registrars for Terrell County, Georgia.
- In their official capacities, the defendants administered voter registration for elections conducted in the state.
- The defendants engaged in various practices and used devices to discriminate against African American citizens who attempted to register to vote.
- This discrimination was based solely on the race or color of the prospective voters.
- The defendants' actions deprived qualified African American citizens of their right to vote.
Procedural Posture:
- The United States sued James Griggs Raines and other Georgia election officials in the U.S. District Court for the Middle District of Georgia, a federal trial court.
- The lawsuit sought an injunction to stop the officials from engaging in racially discriminatory voter registration practices, as authorized by the Civil Rights Act of 1957.
- The defendants filed a motion to dismiss the complaint.
- The District Court granted the defendants' motion and dismissed the complaint.
- The trial court held that the relevant provision of the Civil Rights Act was unconstitutional because it could be interpreted to apply to purely private action, which the court believed exceeded Congress's power under the Fifteenth Amendment.
- The United States, as the appellant, filed a direct appeal of the dismissal to the Supreme Court of the United States.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
May state officials, against whom a provision of the Civil Rights Act of 1957 is constitutionally applied, challenge that provision as facially unconstitutional on the grounds that it might be unconstitutionally applied to purely private actors in circumstances not before the court?
Opinions:
Majority - Justice Brennan
No. A party cannot challenge the constitutionality of a statute based on its potential application to others if the statute is constitutionally applied to the party itself. Federal courts have a duty to avoid deciding constitutional questions in advance of the necessity of deciding them and should never formulate a rule of constitutional law broader than is required by the precise facts of the case. Here, the defendants are state officials charged with racial discrimination in voting, which is clearly 'state action' prohibited by the Fifteenth Amendment. The Civil Rights Act of 1957 is 'appropriate legislation' under that Amendment to remedy such conduct. Because the statute is plainly constitutional as applied to these defendants, they lack standing to challenge it based on a hypothetical, unconstitutional application to private individuals.
Concurring - Justice Frankfurter
Yes, the complaint should not have been dismissed. Justice Frankfurter agrees with the judgment, stating that the Civil Rights Act of 1957 is presumptively valid and is sustained here under familiar principles of constitutional law. He finds it unnecessary to canvass the multitude of opinions cited by the majority, as he believes the correct result is straightforward and not obstructed by prior decisions like Barney v. City of New York.
Analysis:
This decision strongly reaffirms the principle of judicial self-restraint and the traditional rules of standing, limiting who can bring constitutional challenges. It prevents litigants from making broad facial challenges to a statute's validity by imagining hypothetical unconstitutional applications, except in limited areas like the First Amendment. By refusing to rule on the statute's application to private actors, the Court preserved the core enforcement power of the Civil Rights Act of 1957 against state officials, a critical tool for protecting voting rights, without prematurely defining the outer limits of Congress's power under the Fifteenth Amendment.
Unlock the full brief for United States v. James Griggs Raines et al.