Williams v. Mississippi
18 S. Ct. 583, 170 U.S. 213, 1898 U.S. LEXIS 1540 (1898)
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Rule of Law:
A state law that is facially neutral and does not explicitly discriminate on the basis of race does not violate the Fourteenth Amendment's Equal Protection Clause merely because it grants discretion to administrative officials, unless it is proven with specific evidence that this discretion is being exercised with an "evil eye and an unequal hand" to systematically discriminate.
Facts:
- Henry Williams, a Black man, was indicted for murder in Washington County, Mississippi.
- The indictment was issued by a grand jury composed exclusively of white citizens.
- The petit jury panel selected for his trial was also composed exclusively of white citizens.
- Mississippi's 1890 Constitution and its statutes required potential voters to, among other things, be able to read any section of the state constitution, or understand it when read to them, or give a reasonable interpretation thereof.
- The laws granted administrative officers the discretion to determine whether an applicant met these qualifications.
- Under Mississippi law, only qualified electors were eligible to serve as grand or petit jurors.
- Williams alleged that the intent and practical effect of these voter qualification laws was to disenfranchise Black citizens on account of their race.
- This disenfranchisement, Williams argued, resulted in the exclusion of Black citizens from the juries in his case.
Procedural Posture:
- Henry Williams was indicted for murder in the Circuit Court of Washington County, Mississippi, a state trial court.
- Before trial, Williams filed a motion to quash the indictment, arguing the laws governing juror selection violated the Fourteenth Amendment.
- The trial court overruled the motion.
- Following a trial, Williams was convicted and sentenced to be hanged.
- Williams (as appellant) appealed the conviction to the Supreme Court of Mississippi (the state's highest court), which affirmed the trial court's judgment.
- Williams then petitioned for, and was granted, a writ of error from the Supreme Court of the United States to review the decision of the Supreme Court of Mississippi.
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Issue:
Does Mississippi's constitution and its election laws, which require literacy tests and grant discretion to registrars to determine voter eligibility, violate the Fourteenth Amendment's Equal Protection Clause if they are facially neutral but are alleged, without specific proof of discriminatory application, to be intended to disenfranchise Black citizens and thereby exclude them from jury service?
Opinions:
Majority - Mr. Justice McKenna
No. The Mississippi constitution and its enabling statutes do not violate the Fourteenth Amendment because they are not discriminatory on their face, and there was no evidence presented to show that their actual administration was evil or unequal. The Constitution protects against denials of equal protection that result from the text of a state's laws or from their proven discriminatory administration, not from the mere possibility of discriminatory administration. While the plaintiff alleges that officials use their discretion to disenfranchise Black voters, he failed to provide specific proof of this discriminatory application. The court distinguished this case from Yick Wo v. Hopkins, where there was clear statistical evidence that a facially neutral ordinance was being administered exclusively against Chinese individuals. Here, there is only an allegation that evil administration is possible under the laws, which is insufficient to prove a constitutional violation.
Analysis:
This decision significantly raised the bar for proving an Equal Protection violation against a facially neutral law, requiring plaintiffs to demonstrate actual, systematic discriminatory administration rather than just discriminatory intent or effect. By upholding Mississippi's literacy tests and discretionary registration schemes without proof of their mal-administration, the Court effectively sanctioned a key legal mechanism for the mass disenfranchisement of African Americans across the South. This ruling narrowed the scope of the precedent set in Yick Wo v. Hopkins and created a major obstacle to civil rights litigation that persisted until the passage of the Voting Rights Act of 1965, which specifically targeted such discriminatory tests and devices.
