Facts
- New York required voters to be able to read and write English as a condition of voting.
- Congress enacted § 4(e) of the Voting Rights Act of 1965, barring denial of the vote based on inability to read or write English for persons who completed sixth grade in Puerto Rico schools taught in a language other than English.
- The federal provision protected many New York City residents who migrated from Puerto Rico and were educated in Spanish.
- Registered voters in New York City sued, seeking a declaration that § 4(e) was unconstitutional and an injunction preventing federal and local officials from enforcing or complying with it.
- A three-judge federal district court granted declaratory and injunctive relief, concluding Congress exceeded its enforcement power.
- The Attorney General and the New York City Board of Elections appealed directly to the Supreme Court.
Issues
- Whether § 4(e) is valid “appropriate legislation” enforcing the Fourteenth Amendment under § 5.
- Whether, if valid, § 4(e) preempts New York’s English literacy voting requirement under the Supremacy Clause.
- Whether § 5 permits Congress to secure Fourteenth Amendment guarantees beyond rights previously recognized by the Court in direct constitutional adjudication.
Decision
- The Supreme Court reversed the district court and upheld § 4(e) in a 7–2 decision.
- The Court held that § 4(e) was a proper exercise of Congress’s § 5 power to enforce the Equal Protection Clause.
- Applying a means-end standard drawn from McCulloch v. Maryland, the Court concluded § 4(e) was “plainly adapted” to enforcing equal protection and consistent with the Constitution.
- The Court ruled that, because Congress acted validly under § 5, the Supremacy Clause renders New York’s literacy requirement unenforceable to the extent it conflicts with § 4(e).
- The Court distinguished prior approval of literacy tests in Lassiter as a different question: direct judicial review under the Fourteenth Amendment versus congressional enforcement legislation under § 5.
- In dissent, Justice Harlan (joined by Justice Stewart) argued the majority’s approach risked letting Congress define the substantive meaning of the Fourteenth Amendment rather than enforcing judicially defined limits.
Legal Principles
- Congress has affirmative legislative authority under Fourteenth Amendment § 5 to enforce the Amendment’s guarantees through “appropriate legislation.”
- “Appropriate legislation” under § 5 is assessed under a rational means-end inquiry: whether the statute is plainly adapted to enforcing the Fourteenth Amendment and consistent with the Constitution.
- Congress’s § 5 power is not confined to prohibiting only conduct already held unconstitutional by the Court; Congress may enact measures aimed at securing equal protection in practical operation.
- When Congress validly exercises § 5 power, conflicting state election laws must yield under the Supremacy Clause.
- State authority to set voter qualifications remains broad but is subject to limits imposed by the Fourteenth Amendment and valid federal enforcement legislation.
Conclusion
The Court sustained § 4(e) as a constitutional use of Congress’s Fourteenth Amendment § 5 enforcement power and held that the federal protection for certain Puerto Rico–educated voters preempted New York’s English literacy voting requirement where the two conflicted.