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Literacy test fails voting rights test (Katzenbach v. Morgan & Morgan)

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Quimbee Case of the Week: Katzenbach v. Morgan & Morgan

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The Voting Rights Act of 1965 was passed by Congress as part of an effort to guarantee the voting rights of all citizens, regardless of race. The VRA included a provision guaranteeing that anyone who completed the sixth grade at an accredited school in Puerto Rico could not be denied the right to vote on the basis of an inability to read or write in English.

Meanwhile, in the 1960s, New York state law required all would-be voters to pass a literacy test in English. New York state officials claimed that the purpose of the law was to ensure that immigrants learned English and were able to intelligently exercise the franchise, but members of New York City’s large Puerto Rican population argued that the state was attempting to disenfranchise non-English speakers.

Morgan and other registered voters in the state brought suit against the United States Attorney General, Nicholas Katzenbach, whose job included enforcing the VRA. The plaintiffs argued that the VRA unconstitutionally usurped the rights of the states and sought to block its enforcement.

Ultimately, the case reached the United States Supreme Court, which upheld the validity of the VRA under Congress’s Fourteenth Amendment power to enforce the Equal Protection Clause in Katzenbach v. Morgan & Morgan, 384 U.S. 641 (1966).

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