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Case Name Katzenbach v. Morgan VR-DC-1172
Docket / Court 1915-65 ( D.D.C. )
State/Territory District of Columbia
Case Type(s) Election/Voting Rights
Special Collection Civil Rights Division Archival Collection
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) ... read more >
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).

Ben Marvin-Vanderryn - 11/14/2021


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Issues and Causes of Action
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Issues
Constitutional Clause
Equal Protection
Federalism (including 10th Amendment)
Defendant-type
Jurisdiction-wide
Discrimination-basis
Language discrimination
General
Voting
Voting access
Language
Spanish
Plaintiff Type
Private Plaintiff
Voting
Election administration
Vote dilution
Voter qualifications
Causes of Action Ex parte Young (federal or state officials)
Defendant(s) New York City Board of Elections
United States
Plaintiff Description Two New York City voters
Class action status sought No
Class action status outcome Not sought
Filed Pro Se No
Prevailing Party Defendant
Public Int. Lawyer No
Nature of Relief None
Source of Relief Litigation
Filed 08/06/1965
Case Closing Year 1966
Case Ongoing No
Additional Resources
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  Katzenbach v. Morgan
Oyez
Date: Jun. 13, 1966
By: Oyez
[ Detail ] [ External Link ]

Court Docket(s)
No docket sheet currently in the collection
General Documents
U.S. Supreme Court
10/01/1965
Brief for the Appellants
VR-DC-1172-0001.pdf | Detail
Source: ABA Supreme Court Briefs
D.D.C.
01/24/1966
Opinion (247 F.Supp. 196)
VR-DC-1172-0003.pdf | WESTLAW| LEXIS | Detail
Source: Westlaw
U.S. Supreme Court
03/21/1966
Brief for Appellees
VR-DC-1172-0004.pdf | Detail
Source: Westlaw
U.S. Supreme Court
06/13/1966
Opinion (384 U.S. 641)
VR-DC-1172-0002.pdf | WESTLAW| LEXIS | Detail
Source: Westlaw
show all people docs
Judges Harlan, John Marshall (Second Circuit, SCOTUS) show/hide docs
VR-DC-1172-0002
Holtzoff, Alexander (D.D.C.) show/hide docs
VR-DC-1172-0003
Stewart, Carl E. (Fifth Circuit) show/hide docs
VR-DC-1172-0002
Plaintiff's Lawyers Avins, Alfred (Tennessee) show/hide docs
VR-DC-1172-0004
Defendant's Lawyers Barrett, St. John (District of Columbia) show/hide docs
VR-DC-1172-0001
Claiborne, Louis F. (District of Columbia) show/hide docs
VR-DC-1172-0001
Doar, John (District of Columbia) show/hide docs
VR-DC-1172-0001
Kauder, Louis (District of Columbia) show/hide docs
VR-DC-1172-0001
Marshall, Thurgood (District of Columbia) show/hide docs
VR-DC-1172-0001
Pergam, Albert S. (District of Columbia) show/hide docs
VR-DC-1172-0001
Spritzer, Ralph S. (District of Columbia) show/hide docs
VR-DC-1172-0001

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