Facts
- North Carolina required prospective voters to read and write a section of the state constitution in English.
- Louise Lassiter, a Black citizen of Northampton County, sought to register but refused to submit to the literacy test.
- The county registrar denied her application for refusing the test.
- On appeal, the Northampton County Board of Elections held a de novo hearing and again denied registration for the same reason.
- Lassiter challenged the requirement under the Fourteenth, Fifteenth, and Seventeenth Amendments in state court; the Superior Court and the Supreme Court of North Carolina affirmed the denial.
- Lassiter then sought review in the U.S. Supreme Court.
Issues
- Whether a state literacy test for voter registration violates the Fourteenth Amendment when it is facially neutral and applied to all voters without proof of discriminatory administration.
- Whether a facially neutral literacy requirement constitutes a denial or abridgment of the right to vote “on account of race” in violation of the Fifteenth Amendment absent evidence of discriminatory purpose or application.
- Whether such a literacy test conflicts with the Seventeenth Amendment’s provision for popular election of U.S. Senators.
Decision
- The Supreme Court unanimously affirmed.
- The Court held that a state may, consistent with the Fourteenth and Seventeenth Amendments, require literacy as a voter qualification if applied to all voters regardless of race.
- The Court held the literacy requirement did not violate the Fifteenth Amendment on its face because it was race-neutral and the record did not show discriminatory administration.
- Because Lassiter refused to take the test, the record provided no basis to evaluate discriminatory grading or application to her.
Legal Principles
- States have broad authority to set voter qualifications, subject to specific constitutional limits.
- A literacy test is not unconstitutional per se under the Fourteenth or Seventeenth Amendments if it is facially neutral and generally applicable.
- A law that is neutral on its face does not violate the Fifteenth Amendment absent proof it was enacted or applied as a device for racial discrimination.
- The constitutionality of a voting qualification may turn on evidence of discriminatory administration, not solely on historical associations with discriminatory devices.
- State voting qualifications remain subject to restrictions imposed by Congress pursuant to its constitutional powers.
Conclusion
The Court upheld North Carolina’s literacy test as a permissible voter qualification because it was facially race-neutral and the record contained no showing of discriminatory purpose or discriminatory administration in Lassiter’s case.