Katzenbach v. Morgan and Morgan

Brief Fact Summary. New York State required English literacy as a prerequisite to voting. The State Attorney General alleges that Section: 4(e) of the Voting Rights Act of 1965 (the Act) can only be sustained if the Court determines New York’s requirement violates the Equal Protection Clause of the Fourteenth Amendment of the United States Constitution (Constitution).

Synopsis of Rule of Law. A congressional enactment under Section: 5 of the Fourteenth Amendment of the Constitution (Section:5 of the Fourteenth Amendment) is effective if it is “plainly adapted to [its] end” and consistent with “the letter and spirit of the constitution.”

Facts. The Act prohibits denying voting rights to individuals who have successfully completed the sixth grade in a school accredited by the Commonwealth of Puerto Rico, on the basis of English illiteracy. The State of New York contends that the Act can only be given effect if the New York literacy requirement violates the Equal Protection Clause of the Fourteenth Amendment.

Issue. Does Section: 5 of the Fourteenth Amendment allow Congress to overturn state legislation without a judicial determination that the state legislation violates the Fourteenth Amendment?

Held. Yes. Appeals court ruling affirmed.
The Supreme Court of the United States (Supreme Court) establishes the test that a Congressional enactment under Section: 5 of the Fourteenth Amendment if it is plainly adapted and consistent with the letter and spirit of the constitution.
In the current case, both prongs of the test are met: the Act specifically prohibits denying voting rights to a class of voters.

Dissent. Justice John Marshall Harlan (J. Harlan) dissents not so much on the general test the Supreme Court of the United States (Supreme Court) develops, but on grounds that Congress must still have constitutional bounds on its powers. In this case, he believes Congress has overstepped its authority by regulating what is essentially a states rights issue.

Discussion. The majority states that the Appellant’s view of Congressional authority under Section: 5 of the Fourteenth Amendment invalidates the text. Why would Section: 5 of the Fourteenth Amendment be necessary if Congress could only overturn legislation that the courts could invalidate on their own?