Minor v. Happersett
Minor v. Happersett was a pivotal Supreme Court case in 1875 involving Virginia Minor, a prominent feminist advocate who sought to register to vote in Missouri. Minor argued that her denial was a violation of her rights as guaranteed by the Fourteenth Amendment, specifically citing the citizenship and privileges and immunities clauses. The Supreme Court, however, unanimously ruled against her, stating that voting qualifications were a matter of state jurisdiction and had never been historically recognized as an inherent right for all citizens. Chief Justice Morrison R. Waite emphasized that the absence of a guaranteed right to vote in the Fourteenth Amendment was the reason the Fifteenth Amendment was necessary. This ruling underscored the legal framework of voter rights at the time and affirmed state control over suffrage. The precedent set by Minor v. Happersett remained influential until the ratification of the Nineteenth Amendment in 1920, which granted women the right to vote. Later, the Supreme Court's interpretation of the Fourteenth Amendment evolved in Reynolds v. Sims (1964), reflecting a shift towards recognizing equality in voting rights. The case is significant in understanding the historical context of women’s suffrage and the legal challenges surrounding voting rights in the United States.
Minor v. Happersett
Date: March 9, 1875
Citation: 21 Wall. (88 U.S.) 162
Issues: Citizenship; right to vote
Significance: The Supreme Court ruled that states could constitutionally refuse to allow women citizens the right to vote.
Virginia Minor, a feminist leader, was denied the right to register to vote in Missouri. She argued that the state’s voter registration officer, Reese Happersett, had violated her rights, which were protected by the citizenship and the privileges and immunities clauses of the Fourteenth Amendment. The Supreme Court unanimously rejected her claim. Speaking for the Court, Chief Justice Morrison R. Waite wrote that voting qualifications had always been left to the states and that historically the states had never recognized that all citizens had an inherent right to vote. The reason that the Fifteenth Amendment had been necessary, moreover, was that the Fourteenth Amendment did not guarantee a right to suffrage. “If the law is wrong,” he noted, “it ought to be changed; but the power for that is not with us.”
The Minor precedent remained in effect until the ratification of the Nineteenth Amendment in 1920. In Reynolds v. Sims (1964), the Court tacitly abandoned Minor and interpreted the Fourteenth Amendment so that it protected an equality of voting rights.