Sunday, December 8, 2013

South Carolina v. Katzenbach case brief

South Carolina v. Katzenbach case brief summary
383 U.S. 301 (1966)

Plaintiff State filed a bill of complaint against defendant attorney general to contest the constitutionality of certain remedial provisions of the Voting Rights Act of 1965 (Act), 42 U.S.C.S. § 1973.

The State argued that, among other things, the complained of provisions of the Act exceeded the powers of Congress and encroached on an area reserved to the states.

  • The court found that Congress was not limited to forbidding violations of the Fifteenth Amendment in general terms and, as against the reserved powers of the states, Congress could use any rational means to effectuate the constitutional prohibition of racial discrimination in voting. 
  • The court found that congress was justified in limiting the operation of the Act through the use of a formula to only a handful of states because the record indicated that actual voter discrimination occurred in these states. 
  • The court found that the temporary suspension of voter qualifications, such as literacy tests, were not unconstitutional because the record indicated that such tests were traditionally used to disenfranchise minorities and their suspension was a legitimate response to the problem. 
  • The court found that the suspension of new voter qualifications pending review was constitutional because the record indicated that states often enacted new laws to perpetuate discrimination in the face of adverse federal court decrees.

The court dismissed the State's bill of complaint.

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