Katzenbach v. Morgan & Morgan case brief

Katzenbach v. Morgan & Morgan case brief summary
384 U.S. 641 (1966)

CASE SYNOPSIS

Appellee registered voters challenged the constitutionality of § 4(e) of the Voting Rights Act of 1965, 42 U.S.C.S. § 1973b(e), because it precluded enforcement of N.Y. Constitutional art. II, § 1and N.Y. Elec. Law § 150, which imposed English literacy requirements on the right to vote. Appellant attorney general challenged the order of the United States District Court for the District of Columbia, which entered judgment for appellees.

CASE FACTS

• Appellee registered voters challenged the constitutionality of § 4(e) of the Voting Rights Act of 1965, 42 U.S.C.S. § 1973b(e), which provided that no person who met specified educational requirements could be denied the right to vote due to inability to speak or write English, insofar as the Act prohibited enforcement of N.Y. Constitutional art. II, § 1 and N.Y. Elec. Law § 150, which provided that no person could become entitled to vote unless such person was also able, except for physical disability, to read and write English. 
• The district court granted declaratory and injunctive relief to appellees, holding that in enacting § 4(e) Congress exceeded the powers granted to it by the Constitution and usurped powers reserved to the states by U.S. Constitutional Amendment X.

DISCUSSION
Appeal was taken directly to the Court, which reversed. It held that under the McCulloch v. Maryland standard, § 4 of the Act was "plainly adapted" to furthering the Equal Protection Clause and that its remedies constituted means consistent with the letter and spirit of the constitution. It therefore held that the state English literacy requirement could not be enforced to the extent that it was inconsistent with § 4(e) of the Act.

CONCLUSION

The Court reversed the lower court's judgment.