Williams v. Mississippi
Williams v. Mississippi, 170 U.S. 213 (1898) is a United States Supreme Court case that reviewed provisions of the state constitution that set requirements for voter registration. The Supreme Court did not find discrimination in the state's requirements for voters to pass a literacy test and pay poll taxes, as these were applied to all voters.
|Williams v. Mississippi|
|Decided April 25, 1898|
|Full case name||Henry Williams v. State of Mississippi|
|Citations||170 U.S. 213 (more)|
|There is no discrimination in the state's requirements for voters to pass a literacy test and pay poll taxes, as these were applied to all voters.|
|Majority||McKenna, joined by unanimous|
|Voting Rights Act (1965), 42 U.S.C. §§ 1973–1973aa-6|
The Court considered the new Mississippi constitution passed in 1890. It upheld disfranchisement clauses which established requirements for literacy tests and poll taxes paid retroactively from one's 21st birthday as prerequisites for voter registration. A grandfather clause effectively exempted illiterate whites, but not blacks, from the literacy test by relating qualifications to whether one's grandfather had voted before a certain date. Because the provisions applied to all potential voters, the Court upheld them, although in practice the provisions had discriminatory effects on African Americans.
The plaintiff, Henry Williams, had been indicted for murder by an all-white grand jury, and convicted by an all-white petit jury and sentenced to be hanged. The plaintiff challenged the jury selection as the jury was selected from eligible voters and the plaintiff alleged the trial was inappropriate as the "defendant's race would have been represented impartially on the grand jury which presented this indictment," and that he was deprived of equal protection under the law.
Williams' counsel, Cornelius J. Jones, attacked the indictment and trial for violating the Equal Protection Clause of the Fourteenth Amendment because blacks had been excluded from jury service following their effective disfranchisement under Mississippi's constitution of November 1890. Drafted specifically to disenfranchise black voters, the state constitution's provisions for literacy and poll-tax qualifications essentially eliminated African Americans as voters, and therefore from jury roles, after 1892.
Williams' counsel contended that the state constitution discriminated against blacks by giving unbridled discretion to election officers, who ruled on adequate records of payment of poll taxes and qualification of electors for literacy and understanding to be registered to vote.
The U.S. Supreme Court unanimously rejected Williams' contention in a 9-0 vote, ruling that he had not shown administration of the Mississippi suffrage provision was discriminatory.
Other Southern states created new constitutions with provisions similar to those of Mississippi's through 1908, effectively disfranchising hundreds of thousands of blacks and tens of thousands of poor whites for decades.
Although some northern Congressmen proposed reducing southern states' apportionment of seats in the House of Representatives to reflect the numbers of African Americans who were disfranchised, no action was passed. With one-party rule, white Southern Democrats had a powerful voting block which they exercised for decades, for instance, to reject any Federal legislation against lynching. (See Section Two of the 14th Amendment.)
- Behrens, Angela; Uggen, Christopher; Manza, Jeff (2003). "Ballot Manipulation and the "Menace of Negro Domination": Racial Threat and Felon Disenfranchisement in the United States, 1850–2002" (PDF). American Journal of Sociology. 109 (3): 559–605. doi:10.1086/378647.