Williams v. Mississippi

Williams v. Mississippi
Supreme Court of the United States
Decided April 25, 1898
Full case name	Henry Williams v. State of Mississippi
Citations	170 U.S. 213 (more)
Holding
There is no discrimination in the state's requirements for voters to pass a literacy test and pay poll taxes, as these were applied to all voters.
Court membership
Chief Justice Melville Fuller Associate Justices John M. Harlan · Horace Gray David J. Brewer · Henry B. Brown George Shiras, Jr. · Edward D. White Rufus W. Peckham · Joseph McKenna
Case opinions
Majority	McKenna, joined by unanimous
Overruled by
Voting Rights Act (1965), 42 U.S.C. § 1973–1973aa-6

Williams v. Mississippi, 170 U.S. 213 (1898) is a United States Supreme Court case that reviewed provisions of the state constitution that set requirements for voter registration. The Supreme Court did not find discrimination in the state's requirements for voters to pass a literacy test and pay poll taxes, as these were applied to all voters.

In practice, the subjective nature of literacy approval by white registrars worked to drastically decrease and essentially disfranchise African American voters.

The Court considered the new Mississippi constitution passed in 1890. It upheld disfranchisement clauses which established requirements for literacy tests and poll taxes paid retroactively from one's 21st birthday as prerequisites for voter registration. A grandfather clause effectively exempted illiterate whites, but not blacks, from the literacy test by relating qualifications to whether one's grandfather had voted before a certain date. Because the provisions applied to all potential voters, the Court upheld them, although in practice the provisions had discriminatory effect on African Americans and poor whites.

Facts

The plaintiff, Henry Williams, had been indicted for murder by an all-white grand jury, and convicted by an all-white petit jury and sentenced to be hanged.

Issue

Williams' counsel, Cornelius J. Jones, attacked the indictment and trial for violating the Equal Protection Clause of the Fourteenth Amendment because blacks had been excluded from jury service following their effective disfranchisement under Mississippi's constitution of 1890. Its provisions for literacy and poll-tax qualifications essentially eliminated as voters, and therefore from jury rolls, after 1892.^[1]

Williams' counsel contended that the state constitution discriminated against blacks by giving unbridled discretion to election officers, who ruled on adequate records of payment of poll taxes and qualification of electors for literacy and understanding to be registered to vote.

Result

The U.S. Supreme Court unanimously rejected Williams' contention in a 9-0 vote, ruling that he had not shown administration of the Mississippi suffrage provision was discriminatory.

Dissents

None

Aftermath

Other Southern states created new constitutions with provisions similar to those of Mississippi's through 1908, effectively disfranchising hundreds of thousands of blacks and tens of thousands of poor whites for decades.

Although some northern Congressmen proposed stripping seats from the South's apportionment in the United States Congress to reflect the numbers of African Americans who were disfranchised, no action was passed. With one-party rule, white Southern Democrats had a powerful voting block which they exercised for decades, for instance, to reject any Federal legislation against lynching.

See also

• List of United States Supreme Court cases, volume 170

References

Further reading

• Behrens, Angela; Uggen, Christopher; Manza, Jeff (2003). "Ballot Manipulation and the “Menace of Negro Domination”: Racial Threat and Felon Disenfranchisement in the United States, 1850–2002". American Journal of Sociology 109 (3): 559–605. doi:10.1086/378647. http://www.uakron.edu/centers/conflict/docs/Behrens.pdf. 

External links

• 170 U.S. 213 (Full text of case at Findlaw.com)