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United States v. Classic

Supreme Court of the United States · 1941 · Constitutional Law

Constitutional LawElectionsFederal Criminal LawCongressional ElectionsPrimariesArticle I Section 2Article I Section 4Necessary and Proper Clause

Facts

Louisiana election commissioners conducting a Democratic primary for nomination of a candidate for the U.S. House of Representatives were indicted for conspiring to alter ballots, falsely counting them, and falsely certifying the vote totals. The indictment alleged they changed eighty-three ballots cast for one candidate and fourteen for another so they would be counted for a third candidate. Louisiana law made the primary part of the state election machinery for congressional candidates, and the indictment further alleged that in the district the Democratic nomination was in practice equivalent to election. The charges asserted that qualified voters were deprived of their right to have their ballots counted as cast, and that this deprivation was carried out by state officials acting under color of law.

Issue

Whether qualified voters in a Louisiana congressional primary have a right, secured by the Constitution, to vote and to have their ballots counted as cast, so that conspiracy to falsify the count violates § 19 and willful deprivation of that right by election commissioners acting under color of state law violates § 20. Also, whether Congress has constitutional authority to reach such conduct when it occurs in a primary rather than only at the general election.

Rule

When state law makes a primary election an integral part of the procedure for choosing Representatives in Congress, or when in fact the primary effectively controls that choice, the qualified voter's right to cast a ballot and have it counted in that primary is part of the right secured by Article I, §§ 2 and 4 of the Constitution. Congress may protect that right through appropriate legislation, including §§ 19 and 20 of the Criminal Code. Under § 20, misuse of power possessed by virtue of state law and made possible only because the actor is clothed with state authority is action taken under color of law.

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Ohio law requires recognized political parties to nominate candidates for the U.S. House through a state-run primary conducted by county election boards at public expense. Candidates who lose that primary may not appear on the general-election ballot as party nominees, and precinct officials in Cleveland intentionally miscount valid ballots cast for Maya Patel in that primary.

Do qualified voters have a constitutional right, enforceable through federal criminal legislation protecting rights secured by the Constitution, to have their ballots counted as cast in this primary?

Explanation. The majority held that when state law makes a congressional primary an integral part of the machinery for choosing Representatives, the voter’s Article I right to choose Representatives includes the right to vote and have that ballot counted in the primary. Because Ohio has embedded the primary into the official process for selecting congressional candidates, intentional miscounting there interferes with a right secured by the Constitution.