KATZENBACH V. MORGAN | Civil Rights Litigation Clearinghouse

Case: Katzenbach v. Morgan

1:65-01915 | U.S. District Court for the District of Columbia

Filed Date: Aug. 6, 1965

Closed Date: June 13, 1966

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Case Summary

This case involves a challenge to Section 4(e) of the Voting Rights Act of 1965. New York election law required Puerto Rican voters to prove their English proficiency by showing they had completed education at least through the sixth grade entirely or predominantly in English. However, Section 4(e) prohibited denying the right to vote to anyone educated through sixth grade in Puerto Rico in a language other than English. Two New York voters sued the New York City Board of Elections, whose members had announced they intended to comply with Section 4(e), in the U.S. District Court for the District of Columbia seeking declaratory and injunctive relief to block enforcement of Section 4(e). The plaintiffs alleged the law violated the right of the State of New York to regulate its own elections and diluted the weight of their own votes by allowing people not legally entitled to vote under New York state law to participate in New York elections. In order to defend Section 4(e), the United States intervened as a defendant; as a result, U.S. Attorney General Nicholas Katzenbach became the named defendant in the case.

On November 15, 1965, a three-judge panel of the District Court ruled that Section 4(e) unconstitutionally usurped states’ ability to regulate their own elections, a power the court held had been reserved to the states by the 10th Amendment. 247 F.Supp 196. They issued an injunction to prevent enforcement of Section 4(e).

The defendants appealed directly to the Supreme Court. On June 13, 1966, the Supreme Court upheld Section 4(e), overturning the District Court. 384 U.S. 641. The Court held that Section 4(e) was an appropriate exercise of the congressional power granted under Section 5 of the 14th Amendment to implement and enforce the Equal Protection Clause. As a result, the federal government could enforce the law. In its decision, the Court specifically noted its ruling did not mean the New York law necessarily violated the Equal Protection Clause on its own but was preempted by Section 4(e).

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Summary Authors

Ben Marvin-Vanderryn (11/14/2021)

People

Judge(s)

Harlan, John Marshall (District of Columbia)

Holtzoff, Alexander (District of Columbia)

Stewart, Carl E. (Louisiana)

Attorneys(s) for Plaintiff

Avins, Alfred (Tennessee)

Barrett, St. John (District of Columbia)

Claiborne, Louis F. (District of Columbia)

Doar, John (District of Columbia)

Kauder, Louis (District of Columbia)

Marshall, Thurgood (District of Columbia)

Pergam, Albert S. (District of Columbia)