Katzenbach v. Morgan
Katzenbach v. Morgan is a significant Supreme Court case that addressed the intersection of voting rights and literacy requirements in the United States. The case arose from a New York law mandating English literacy tests for voter registration, which was challenged under the Voting Rights Act of 1965. The Supreme Court, in a 7-2 decision, upheld a provision of the Act that prevented the disenfranchisement of individuals who had completed the sixth grade in accredited Puerto Rican schools due to their inability to read or write English. Justice William J. Brennan, Jr. emphasized that Congress possesses broad authority under the Fourteenth Amendment to legislate on voting rights and interpret the Constitution in ways that enhance civil liberties.
The ruling highlighted a tension between judicial interpretations of constitutional rights and congressional authority to protect those rights. Dissenting opinions, notably from Justice John M. Harlan II, raised concerns about Congress's potential overreach in expanding or limiting constitutional guarantees. This case is often viewed as pivotal in the ongoing struggle for voting rights, particularly for minority groups affected by literacy tests and similar barriers. As such, Katzenbach v. Morgan remains a crucial reference point in discussions about the legal framework supporting equitable access to voting in the United States.
Katzenbach v. Morgan
Date: June 13, 1966
Citation: 384 U.S. 641
Issue: Right to vote
Significance: The Supreme Court recognized the right of Congress to enforce its own interpretation of Fourteenth Amendment rights.
A New York statute required passage of an English literacy test in order to register to vote. In Lassiter v. Northampton County Board of Elections (1959), the Court had held that such literacy requirements did not violate the Fourteenth Amendment. New York’s attorney general argued that Congress could not invoke the enforcement provision of the Fourteenth Amendment to prohibit implementation of a state law when that law had not been judged unconstitutional by the judicial branch.
However, by a 7-2 vote, the Court upheld a provision of the Voting Rights Act of 1965, providing that no person who had completed the sixth grade in an accredited Puerto Rican school could be denied the right to vote because of an inability to read or write English. Speaking for the majority, Justice William J. Brennan, Jr., argued that the Framers of the Fourteenth Amendment intended section 5 to give Congress broad powers to enforce the rights enumerated in the amendment. Brennan wrote, moreover, that Congress had the prerogative of interpreting the U.S. Constitution in ways that expanded on the rights that were recognized by the courts. Justice John M. Harlan II’s dissent warned that if Congress could expand on the Court’s interpretations of constitutional rights, it could logically also restrict some guarantees. Most commentators have concluded that the majority of the justices rejected Brennan’s expansive view of congressional prerogatives in Oregon v. Mitchell (1970).