United States v. Reese
Facts
Two municipal election inspectors in Kentucky were indicted for refusing to receive and count the vote of William Garner, a United States citizen of African descent. After the government abandoned two counts, the remaining counts were based on sections 4 and 3 of the Enforcement Act of 1870. The Court treated the case as turning on whether Congress had validly made it a federal crime for election officials at a state election to refuse a qualified citizen's vote because of race, color, or previous condition of servitude. The opinion focused on the statutory text rather than any broader claim of federal common-law criminal power.
Issue
Whether sections 3 and 4 of the Act of May 31, 1870 were valid and effective exercises of Congress's power under the Fifteenth Amendment to punish inspectors or others who interfere with voting at state elections because of race. More specifically, the question was whether broadly worded penal provisions could be judicially limited to reach only race-based discrimination within Congress's constitutional power.
Rule
The Fifteenth Amendment does not confer the right to vote, but it secures a constitutional right to exemption from discrimination in voting on account of race, color, or previous condition of servitude, which Congress may enforce by appropriate legislation. Congress may punish only conduct at state elections that falls within that constitutional prohibition, and a penal statute that is written in general terms broader than Congress's constitutional authority cannot be saved by judicial insertion of limiting language; each such section must stand or fall as written.
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