What is Lassiter v. Northampton County Bd. of Elections?
Lassiter v. Northampton County Bd. of Elections was a court case that challenged the constitutionality of literacy tests. The case of Lassiter v. Northampton County Bd. of Elections was appealed from the Supreme Court of North Carolina.
The controversy surrounding Lassiter v. Northampton County Bd. of Elections began in a Federal District Court, where the appellant, an African American citizen of North Carolina, sued to have voter-required literacy tests ruled void due to their unconstitutional status. In response to this filing, a three-judge court convened and ruled that the test was part of a state provision that also included a grandfather clause. The court said that this clause plainly would be deemed unconstitutional; however, the North Carolina statute which enforced the registration requirements in the State Constitution had been superseded by previous legislation that did not contain the grandfather clause.
Being uncertain as to the significance of the previous legislation, the court deemed it wise to have all administrative remedies under the previous legislation exhausted before the federal court acted.
Lassiter v. Northampton County Bd. of Elections: The Case
The case of Lassiter v. Northampton County Bd. of Elections began as an administrative proceeding. The appellant applied for registration as a voter but her registration was denied by the registrar because she refused to submit literacy tests as required by the state’s statute. When appealed to the County Board of Elections, the appellant again refused to take the literacy tests. When she appealed to the Superior Court which sustained the lower court’s ruling, she claimed that that the requirement of the tests violated the Fourteenth, Fifteenth and Seventeenth Amendments of the Federal Constitution.
In response to another rejection, the Appellant appealed to the North Carolina Supreme Court which further affirmed the lower court’s ruling. The literacy test was ruled a fundamental part of the North Carolina Constitution.
The opinion of the court rendered in Lassiter v. Northampton County Bd. of Elections and delivered by Chief Justice Douglas, held that the provided tests were applied equally to all races and were not meant to promote racial discrimination. The court in Lassiter v. Northampton County Bd. of Elections went onto say that the tests did not contravene any restriction that Congress, acting in pursuance to its constitutional powers, had imposed. As a result, in Lassiter v. Northampton County Bd. of Elections, the court stated that the literacy test then can be an allowable use of the state’s power to determine the conditions under which the right of suffrage may be utilized or exercised. In response to the ruling rendered in Lassiter v. Northampton County Bd. of Elections, the United States Congress subsequently prohibited an assortment of tests belonging in the National Voting Rights Act of 1965.