United States v. Reese
"United States v. Reese" is a significant Supreme Court case that emerged from an incident involving a Kentucky election official who refused to accept an African American's vote, leading to an indictment under the 1870 Enforcement Act. This act was designed to uphold the voting rights guaranteed by the Fifteenth Amendment, which prohibits racial discrimination in voting. The Supreme Court, in an 8-1 decision delivered by Justice Morrison R. Waite, ruled that the provision of the Enforcement Act regarding the refusal to accept a vote was flawed due to its failure to replicate the exact language of the Fifteenth Amendment. The Court established that voting is a privilege rather than an absolute right, affirming that if a state chooses to offer this privilege, it cannot exclude voters based on race.
While the ruling upheld the Enforcement Act for federal elections, it did not extend protections to state and local elections, inadvertently permitting southern states to implement discriminatory practices such as poll taxes and literacy tests to disenfranchise African American voters. This case highlights the complexities and challenges of enforcing voting rights in the United States and reflects the ongoing struggle against racial discrimination in the electoral process.
United States v. Reese
Date: March 27, 1876
Citation: 92 U.S. 214
Issues: Fifteenth Amendment; right to vote
Significance: The Supreme Court voided part of the 1870 Enforcement Act, claiming that voting was a privilege, not a right.
After refusing to accept an African American’s vote, a Kentucky election official was indicted under the 1870 Enforcement Act, which enforced the voting rights provided by the Fifteenth Amendment. Justice Morrison R. Waite wrote the opinion for the 8-1 majority, striking down a section of the 1870 act regarding refusal to accept a vote on the grounds that the statute did not repeat the precise language of the Fifteenth Amendment. The Supreme Court affirmed that voting was a privilege, not a right, but held that if a state offered the privilege, it must not exclude voters on racial grounds. The Court upheld the enforcement act for federal elections, but by omitting state and local elections with its very narrow rulings, the Court allowed southern states to disenfranchise African Americans through poll taxes and literacy, character, and other tests.
