Guinn v. United States
**Overview of Guinn v. United States**
Guinn v. United States is a significant Supreme Court case that addressed the issue of voting rights in the context of discriminatory practices employed to disenfranchise African American voters. The case centered on a grandfather clause included in the Oklahoma state constitution, which allowed individuals to bypass literacy tests for voting if their ancestors had been eligible to vote before the Fifteenth Amendment was ratified. This provision effectively exempted many white voters from educational requirements while disenfranchising African Americans, who were largely denied the right to vote prior to the amendment.
In the 1915 ruling, the Supreme Court struck down the Oklahoma grandfather clause, declaring it unconstitutional due to its discriminatory nature. The decision, reached by an 8-1 vote and articulated by Justice Edward D. White, highlighted the clause as a clear attempt to obstruct African American participation in elections. Despite its historical importance, the ruling had limited immediate impact, as other states continued to employ similar discriminatory measures, such as literacy tests, without any obligation for fairness. The Guinn case exemplifies the ongoing struggle against racially motivated disenfranchisement in the United States.
Guinn v. United States
Date: June 21, 1915
Citation: 238 U.S. 347
Issues: Right to vote; race discrimination
Significance: The Supreme Court struck down grandfather clauses as a violation of the Fifteenth Amendment.
Grandfather clauses indirectly discriminated against African Americans, usually by waiving the literacy requirement for voting to those whose ancestors had been entitled to vote before the ratification of the Fifteenth Amendment. As late as Giles v. Harris (1903), the Supreme Court had declared it did not have authority to prohibit indirect barriers on voting. In 1908 the Oklahoma state constitution was amended to include a literacy test with a grandfather clause.
By an 8-1 vote, the Supreme Court found that the clause was unconstitutional. Justice Edward D. White reasoned that the measure was a transparent obstacle that applied to black but not to white voters. The Guinn decision, despite its symbolic importance, had limited practical effect. By 1915 Georgia was the only other state with an unexpired grandfather clause. In addition, White’s opinion explicitly endorsed the continuation of literacy tests, without any specific requirements for fairness in testing.