United States v. Mississippi

Supreme Court of the United States · 1965 · Federal Courts

Federal Courts42 U.S.C. § 1971Fifteenth AmendmentAttorney General enforcementstate as defendantvoting rightsracial discriminationjoinder

Facts

The complaint alleged that Mississippi had, since 1890, adopted constitutional provisions, statutes, rules, and practices designed to restrict Negro voting and maintain white political supremacy. It challenged literacy, interpretation, citizenship-understanding, and good-moral-character requirements, as well as record-destruction and 1962 registration procedures that allegedly gave registrars broad discretion to discriminate against Negro applicants. The United States sought declaratory and injunctive relief, including an order barring enforcement of the challenged laws and practices and requiring registration of qualified Negro applicants. The district court dismissed the suit, ruling among other things that the United States could not sue the State, that the election commissioners were improper parties, and that the registrars were misjoined and improperly venued.

Issue

Whether the complaint stated a claim for relief under 42 U.S.C. § 1971 and the Fifteenth Amendment, and whether the United States could maintain that suit against Mississippi, the state election commissioners, and the county registrars in a single action. Also at issue was whether dismissal on joinder and venue grounds was proper.

Rule

Under 42 U.S.C. § 1971(a) and (c), the Attorney General may bring suit for preventive relief to protect citizens' right to vote without racial discrimination, including suits challenging unconstitutional state voting laws and practices. The phrase "otherwise qualified by law" refers to qualifications imposed by valid state or federal law, not unconstitutional state enactments. Section 1971(c) authorizes joining the State as a defendant when state officials are alleged to have committed acts depriving citizens of voting rights secured by § 1971(a), and the United States may constitutionally sue a State to enforce the Fifteenth Amendment. Where multiple registrars are alleged to participate in a statewide discriminatory system, joinder under Rule 20(a) and venue are proper.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The Attorney General files suit in federal court against the State of Franklin, alleging that its voter-registration laws include vague "civic understanding" and "character" requirements that are used to deny Black citizens registration because of race. Franklin argues the United States may sue only when local officials misapply otherwise valid laws, not when the complaint attacks the validity of the state laws themselves.

How should the court rule on Franklin's argument?

Explanation. The majority read § 1971(a) and (c) broadly. It held that Congress expressly authorized the Attorney General to bring suit for preventive relief when acts or practices would deprive citizens of the right to vote without racial discrimination. That authorization includes suits challenging discriminatory state voting laws themselves, not just unequal enforcement of otherwise valid laws.