## Facts

- Oklahoma adopted a literacy test with a “grandfather clause” that effectively exempted many white voters while excluding many Black voters; the clause was invalidated under the Fifteenth Amendment.
- Oklahoma then enacted a 1916 registration statute that:
  - Automatically preserved voting eligibility for those who voted in the 1914 general election.
  - Required all others to register during a 12-day window in 1916 (with a limited extension for county absences).
  - Permanently disqualified those who did not register during that period.
- I. W. Lane, a Black citizen of Oklahoma, attempted to register to vote in 1934 but was refused by county registration officials.
- Lane sued the officials for damages under Revised Statutes § 1979 (now 42 U.S.C. § 1983), alleging the registration scheme and its administration denied him the right to vote because of race.

## Issues

1. Whether a person denied voter registration under color of a state registration statute that violates the Fifteenth Amendment may sue state officials for damages under R.S. § 1979 (now § 1983) without first exhausting state judicial remedies.
2. Whether Oklahoma’s 1916 registration scheme—preserving eligibility for 1914 voters while permanently disenfranchising others who missed a brief 1916 registration window—violated the Fifteenth Amendment.

## Decision

- The Supreme Court reversed the judgment for the defendants.
- The Court held that a federal damages action under R.S. § 1979 was available against registration officials who denied registration under color of a state law that discriminated in violation of the Fifteenth Amendment.
- The Court held Lane was not required to exhaust state judicial remedies before bringing the federal damages action.
- The Court held Oklahoma’s 1916 registration system was unconstitutional because it functioned as a substitute for the invalid grandfather clause and perpetuated racial discrimination in voting.

## Legal Principles

- The Fifteenth Amendment forbids both direct racial exclusions from voting and facially neutral devices designed or operating to continue racial disenfranchisement (“sophisticated as well as simple-minded” discrimination).
- Courts may assess a voting law’s structure and practical operation, not merely its neutral wording, when determining whether it violates the Fifteenth Amendment.
- State officials who, under color of state law, deny voter registration pursuant to a racially discriminatory scheme may be liable for damages under R.S. § 1979 (now 42 U.S.C. § 1983).
- A plaintiff bringing a federal civil-rights damages action for denial of voting rights is not required to exhaust state judicial remedies before suing in federal court.

## Conclusion

The Court invalidated Oklahoma’s post-Guinn registration scheme because it preserved advantages gained from earlier unconstitutional exclusions and imposed permanent disenfranchisement through a one-time, short registration window, and it confirmed a direct federal damages remedy under § 1983 without prior exhaustion of state judicial remedies.


Lane v. Wilson, 307 U.S. 268 (1939)