Minor v. Happersett Case Brief: Supreme Court Decision on Women's Voting Rights in 1874

Case Brief: Minor v. Happersett

Citation

Minor v. Happersett, 88 U.S. 162 (1874)

Court

Supreme Court of the United States

Facts

The case arose when Virginia Minor, a woman from Missouri, attempted to register to vote in 1872. She was denied registration based on the argument that, as a woman, she was not entitled to vote under the laws of the time. Virginia, along with her husband, sued the election officials, including John Happersett, arguing that the Fourteenth Amendment's privileges and immunities clause guaranteed her the right to vote.

Issue

Does the right to vote fall within the protections provided by the Fourteenth Amendment, and are women entitled to the same voting rights as men under this amendment?

Rule

The Supreme Court held that the right to vote is not a fundamental right protected by the privileges and immunities clause of the Fourteenth Amendment.

Application

The Court analyzed the historical context of voting rights and the intention behind the Fourteenth Amendment. It noted that while states could not deny citizens privileges or immunities without due process, the right to vote was not explicitly mentioned as a fundamental right protected by the Constitution. The Court argued that voting was a privilege granted by states and that states had the authority to regulate who could vote.

The justices emphasized that the Constitution did not confer the right to vote on women specifically and that this matter was left to state legislatures. The Court ultimately upheld the Missouri law denying women the right to vote, concluding that Virginia Minor had no legal basis to claim her voting rights under the Constitution.

Conclusion

The Supreme Court ruled against Virginia Minor, reinforcing the idea that voting rights were determined by state law rather than federal constitutional protection. This decision highlighted the ongoing struggle for women's suffrage in the United States, which would continue until the ratification of the Nineteenth Amendment in 1920.