Citation. 189 U.S. 475 (1903)
Brief Fact Summary.
Giles (Plaintiff) challenged provisions in the Alabama constitution that resulted in the systematic disenfranchisement of blacks in the state as being unconstitutional. (The remainder of the factual background and procedural posture is omitted from the casebook.)
Synopsis of Rule of Law.
(The Court did not address the constitutional issue raised by the case.)
Plaintiff was a black man who had voted in Alabama. He sought the invalidation of provisions in the Alabama constitution that effected a systemic disenfranchisement of blacks in the state. Plaintiff argued that the provisions violated the U.S. Constitution and sought to have disenfranchised blacks placed on the voter registration rolls.
(The legal and constitutional issue raised in the case is omitted from the casebook.)
(Holmes, J.) (The Court did not address the constitutional issue raised by the case.) Even if Plaintiff’s assertions are true, the Court cannot grant any relief that will practically result in the changes Plaintiff seeks. Ordering the addition of names to the voter rolls would be an empty gesture because without Court supervision of voting in Alabama, nothing will actually change. Change must be made through the state or federal legislatures.
By not addressing the underlying issue, the Court essentially upheld the disenfranchising provisions present in the constitutions of many southern states. Eventually, the Court issued opinions affirming that the right to vote is protected by the Equal Protection Clause of the Fourteenth Amendment and that federal courts may address these constitutional violations within the states.