Guinn & Beal v. United States
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| Guinn & Beal v. United States | |
| Reference: 238 U.S. 347 | |
| Term: 1915 | |
| Important Dates | |
| Argued: October 17, 1913 Decided: June 21, 1915 | |
| Outcome | |
| United States Court of Appeals for the Eighth Circuit affirmed | |
| Majority | |
| Edward Douglass White • Joseph McKenna • Oliver Holmes • William R. Day • Willis Van Devanter • Mahlon Pitney • Louis Brandeis • John Clarke | |
Guinn & Beal v. United States was a case decided 8-0 on June 21, 1915, by the United States Supreme Court holding that the Grandfather Clause, which required voters to pass a reading test with the exception of all those who were entitled to vote on January 1, 1866, just after the Civil War ended but before Black men were granted the right to vote in 1870, violated the Fifteenth Amendment of the U.S. Constitution by discriminating against Black male voters. The court affirmed the decision of the United States Court of Appeals for the Eighth Circuit.[1][2]
Why it matters: The Supreme Court's decision found that the Grandfather Clause of Oklahoma's Voter Registration Act of 1910 did violate the Fifteenth Amendment outlined in the U.S. Constitution, which granted all men of all racial identities the right to vote. To read more about the impact of Guinn & Beal v. United States click here.
Background
On the day of the Oklahoma general election in 1910, African American residents C. W. Stephenson, Alfred M. Keel, Green Baucom, Sam Fort, Fred McCann, Oliver Andrews, Thomas Pettis, and W. T. Smith went to vote. Each of these men was turned away by election officials Frank Guinn and J. J. Beal. Under Oklahoma’s former constitution, all these men were eligible to vote. But, due to the passing of a recent amendment to the Oklahoma Constitution called the Grandfather Clause, the election officials turned these voters away. The Grandfather Clause required voters to pass a reading test with the exception of all those who were permitted to vote on January 1, 1866, just after the Civil War ended. However, the Fifteenth Amendment, which guaranteed voting rights for Black men, was passed in 1870. Therefore, all Black men in Oklahoma did not meet the requirements of the Grandfather Clause to be considered exempt from taking a literacy test in order to vote. Oftentimes, even if Black voters were able to take the literacy test, they still may not have passed because the tests used were difficult, even sometimes described as impossible.
Guinn and Beal were indicted on June 13, 1911, for conspiracy to deprive Black men of voting, which violated the 15th Amendment of the U.S. Constitution. Guinn and Beal were found guilty by the local courts. They appealed their decision to the United States Court of Appeals for the Eighth Circuit (the Tenth Circuit Court of Appeals was not created until 1929). Their conviction was affirmed by the Court of Appeals, to which they appealed to the U.S. Supreme Court.[3]
Oral argument
Oral arguments were held on October 17, 1913. The case was decided on June 21, 1915.[2]
Decision
The Supreme Court decided 8-0 to affirm the decision of the United States Court of Appeals for the Eighth Circuit. Chief Justice Edward Douglass White delivered the opinion of the court. Justice James Clark McReynolds did not participate in the decision of the case.[2]
Opinions
Opinion of the court
Chief Justice Edward Douglass White, writing for the court, argued that the Grandfather Clause of Oklahoma's Voter Registration Act of 1910 violated the Fifteenth Amendment of the U.S. Constitution by discriminating against Black male voters based on their race:[2]
| “ | [N]o question is raised by the Government concerning the validity of the literacy test provided for in the amendment under consideration as an independent standard, since the conclusion is plain that that test rests on the exercise of state judgment, and therefore cannot be here assailed either by disregarding the State's power to judge on the subject or by testing its motive in enacting the provision. The real question involved, so the argument of the Government insists, is the repugnancy of the standard which the amendment makes, based upon the conditions existing on January 1, 1866, because, on its face and inherently, considering the substance of things, that standard is a mere denial of the restrictions imposed by the prohibitions of the Fifteenth Amendment, and by necessary result, recreates and perpetuates the very conditions which the Amendment was intended to destroy.[4] | ” |
| —Edward Douglass White, majority opinion in Guinn & Beal v. United States[2] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
Guinn & Beal v. United States held that the Grandfather Clause of Oklahoma's Voter Registration Act of 1910 did violate the Fifteenth Amendment of the U.S. Constitution, which granted Black men the right to vote. The case established the precedent that voting restrictions specifically targeting certain racial groups were unconstitutional.[1][2]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 Oklahoma Historical Society, "Guinn v. United States (1915)," accessed September 27, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 Justia, "Guinn & Beal v. United States, 238 U.S. 347 (1915)," accessed September 27, 2022
- ↑ Oklahoma Bar Association, "Guinn v. U.S.: States' Rights and the 15th Amendment," May, 2021
- ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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