United States v. Reese

United States v. Reese was an 1876 voting rights case in which the United States Supreme Court narrowly construed the 15th Amendment to the United States Constitution, which provided that suffrage for male citizens could not be restricted due to race, color or previous condition of servitude.

This was the Supreme Court's first voting rights case under the Fifteenth Amendment and the Enforcement Act of 1870. A Kentucky electoral official had refused to register an African‐American's vote in a municipal election and was indicted under two sections of the 1870 act: section 2 required that administrative preliminaries to elections be conducted without regard to race, color, or previous condition of servitude; section 3 forbade wrongful refusal to register votes where a prerequisite step “required as foresaid” had been omitted.

The Court held that the Fifteenth Amendment did not confer the right of suffrage, but it prohibited exclusion from voting on racial grounds. The justices invalidated the operative section 3 of the Enforcement Act since it did not repeat the amendment's words about race, color, and servitude. They ruled that the section exceeded the scope of the Fifteenth Amendment.

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