Oregon v. Mitchell, Texas v. Mitchell, and United States v. Arizona
Oregon v. Mitchell, Texas v. Mitchell, and United States v. Arizona are pivotal Supreme Court cases that addressed the constitutionality of voting age regulations following amendments to the Voting Rights Act of 1965. In response to a growing push for uniform voting standards, Congress sought to lower the voting age to eighteen across all elections. However, this federal intervention faced challenges based on the principle of federalism, which grants states the authority to determine their own voting regulations. The Supreme Court's decision in Mitchell established that while Congress had the authority to mandate the voting age for federal elections, it could not extend this power to state and local elections. This split decision reflected deep divisions among the justices regarding the balance of power between federal and state governments. To resolve the confusion stemming from the ruling, Congress quickly proposed the Twenty-sixth Amendment, which was ratified to ensure that the voting age was uniformly set at eighteen in all elections. These cases underscore the ongoing dialogue about voting rights and the complexities of legislative authority within the United States' federal system.
Oregon v. Mitchell, Texas v. Mitchell, and United States v. Arizona
Date: December 21, 1970
Citation: 400 U.S. 112
Issue: Right to vote
Significance: The confusion created by the Supreme Court’s fragmented decision, which established different minimum voting ages for federal and state elections, was eliminated through the passage of the Twenty-sixth Amendment, which made the minimum voting age eighteen in all elections.
As a part of the 1970 amendments to the 1965 Voting Rights Act, Congress not only extended the act for five years but also attempted to standardize residency and age requirements for voting in elections at all levels. The act lowered the voting age to eighteen for federal, state, and local elections. However, because states had previously had the authority to set the minimum voting age, the act was challenged as a violation of federalism. By a 5-4 vote, the Supreme Court ruled that Congress could set the minimum voting age for federal elections but could not do so for state or local elections. Five opinions were filed in the case. Essentially, four justices believed Congress had the power to set the voting age in any election and four did not. Justice Hugo L. Black, who cast the deciding vote, believed that Congress had the power in federal but not state and local elections. To eliminate the confusion and avoid complicated election procedures, Congress proposed the Twenty-sixth Amendment, which lowered the voting age to eighteen in all elections and was quickly ratified.
