Case: United States v. Manning

On April 28, 1961, the U.S Attorney General charged the State of Louisiana and Cecil Manning, the Registrar of Voters for East Carroll Parish, with having engaged in acts preventing people from voting on the basis of race. The action was filed in the Western District of Louisiana, and was assigned to Chief Judge Ben C. Dawkins, Jr. The Attorney General sought injunctive relief, seeking to end the systemic voter registration denial for persons of color. 

At the end of the 1960 voter registration period, no persons of color had registered to vote in the Parish since 1922. Louisiana law required individuals to establish their identities to the "satisfaction of the registrar." Manning used this requirement to discriminate on the basis of race, permitting only people he "knew" to register. This standard exclusively favored white individuals as only they could meet Manning's threshold. Eighteen persons of color had attempted to register to vote, and were turned away for not having two white individuals who could "identify them."

The Court had jurisdiction pursuant to 42 U.S.C.A. § 1971(d), and the Attorney General had authorization under 42 U.S.C.A. § 1971 (c ) to stop the systemic denial of rights and privileges pursuant to 42 U.S.C. § 1971(a) and the 15th Amendment. Since no persons of color had been registered since 1922, despite many attempting to, there was enough evidence to provide relief under both the 14th and 15th Amendments and the Civil Rights Act of 1957. 

The means by which Manning used to register voters was discriminatory per se, violating the Fifteenth Amendment and 42 U.S.C.A. § 1971(a).His actions purposefully denied voter registration access on the basis of race by refusing to make reasonable inquiry to identify potential voters and rejecting reasonable proof of identification. The patterns of racial discrimination violated 42 U.S.C.A. § 1971(e)

The Court ordered the State of Louisiana, the Registrar of Voters of East Carroll Parish, his deputies agents, officers, employees, and successors in office be enjoined from engaging in actions resulting in denying registration to eligible voters on the basis of race. The order prohibited the creation of exclusive means of identification requirements for certain races, and the defendants needed to file a progress report each month, including a list of new registrants, a list of transfers and statistical totals, and a list of the names, addresses, and races of all persons whose applications were rejected. The registration books and records also needed to be publicly available for inspection. 

In July of 1962, the state tried to challenge the constitutionality of the Civil Rights Act, but the action was dismissed in 1963.