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Katzenbach v. Morgan

    Brief Fact Summary. A law that ensured Puerto Ricans the right to vote upon successful completion of the sixth grade was upheld as a valid exercise of the powers of the United States Congress by means of Section:5 of the Fourteenth Amendment of the United States Constitution (Constitution).

    Synopsis of Rule of Law. A federal law ensuring the right to vote upon successful completion of the sixth grade, despite a conflicting state law’s voting qualifications, is a valid exercise of the powers of the United States Congress by means of Section:5 of the Fourteenth Amendment of the Constitution because Section:5 is a positive grant of power.

    Facts. Section 4(e) of the Voting Rights Act of 1965 (the Act) ensures the right to vote to all Puerto Ricans who successfully complete the sixth grade. The Appellees, Morgan and other registered voters in New York City (Appellees), brought this suit to challenge the constitutionality of Section:4(e) of the Act insofar as it pro tanto prohibits the enforcement of the election laws of New York requiring an ability to read and write English.

    Issue. Whether such legislation is, as required by Section:5 of the Fourteenth Amendment of the Constitution, appropriate to enforce equal protection?
    Whether the congressional remedies adopted in Section:4(e) of the Act constitute means which are not prohibited by, but which are consistent with the constitution?

    Held. Yes. Judgment of the lower court reversed. There can be no doubt that Section:4(e) of the Act may be regarded as an enactment to enforce equal protection. Section 4(e) of the Act may be viewed as a measure to secure for the Puerto Rican community residing in New York, nondiscriminatory treatment by the government, both in the imposition of voting qualifications and the administration of governmental services. Section 4(e) of the Act can be readily seen as “plainly adapted” to furthering these claims of equal protection.
    Yes. Section 4(e) of the Act does not restrict or deny the franchise, but in effect extends the franchise to persons who would be denied it by state law. The limitation on relief effected in Section:4(e) of the Act does not constitute a forbidden discrimination since these factors may have been the basis for the decision of Congress to go “no farther than it did.”

    Dissent. Section 4(e) of the Act cannot be sustained except at the sacrifice of the fundamentals in the American constitutional system: the separation between the legislative and judicial function and the boundaries between federal and state political authority.

    Discussion. The majority opinion rested on alternative rationales. First, it held that Section:4(e) of the Act was a measure for the Puerto Rican community residing in New York, ensuring nondiscriminatory treatment by the government. Second, Section:4(e) of the Act eliminates “an invidious discrimination in establishing voter qualifications.”


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