## Facts

- The United States, through the Attorney General, sued county registrars and deputy registrars responsible for voter registration in Terrell County, Georgia.
- The complaint alleged the officials used administrative devices and practices to discriminate against Black citizens seeking to register to vote.
- The United States sought injunctive and related relief under 42 U.S.C. § 1971(a) and (c), enacted in the Civil Rights Act of 1957.
- The alleged misconduct was by state and county officials acting in their official capacities in election administration.

## Issues

1. Whether a federal court may hold § 1971(c) unconstitutional on its face based on possible unconstitutional applications to private conduct, when the case alleges only unconstitutional conduct by public officials.
2. Whether § 1971(c), as applied to authorize the Attorney General to seek an injunction against state officials’ racial discrimination in voter registration, is constitutional under the Fifteenth Amendment.

## Decision

- The Supreme Court reversed the district court and remanded.
- The Court held the district court improperly invalidated § 1971(c) based on hypothetical applications not presented by the complaint.
- The Court held § 1971(c) is constitutional as applied to authorize the Attorney General to seek injunctive relief against racial discrimination by public officials in voter registration.

## Legal Principles

- A litigant to whom a statute is constitutionally applied generally cannot attack it on the ground that it might be unconstitutionally applied in other situations.
- Courts should not exercise the power to invalidate an Act of Congress by reference to hypothetical cases not presented by the facts.
- Under the Fifteenth Amendment, Congress may provide civil enforcement mechanisms, including suits by the Attorney General for preventive relief, to stop racial discrimination in voting by state officials.
- Earlier precedent favoring broad facial invalidation is limited where inconsistent with later doctrine favoring as-applied review.

## Conclusion

The Court allowed the federal government’s injunction action to proceed, holding that Congress may authorize the Attorney General to sue state election officials to prevent racial discrimination in voter registration and that a statute should not be struck down based on speculative unconstitutional applications outside the case before the court.


United States v. Raines, 362 U.S. 17 (1960)