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.”
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.
Here again, it is enough that we perceive a basis upon which Congress might predicate a judgment that the application of New York's English literacy requirement to deny the right to vote to a person with a sixth grade education in Puerto Rican schools in which the language of instruction was other than English constituted an invidious discrimination in violation of the Equal Protection Clause.View Full Point of Law