Williams v. Mississippi
Encyclopedia
Williams v. Mississippi, 170 U.S. 213
(1898) is a United States Supreme Court case that reviewed provisions of the state constitution that set requirements for voter registration. The Supreme Court did not find discrimination in the state's requirements for voters to pass a literacy test
and pay poll taxes, as these were applied to all voters.
In practice, the subjective nature of literacy approval by white registrars worked to drastically decrease and essentially disfranchise African American
voters.
The Court considered the new Mississippi
constitution passed in 1890. It upheld disfranchisement clauses which established requirements for literacy tests and poll taxes paid retroactively from one's 21st birthday as prerequisites for voter registration. A grandfather clause
effectively exempted illiterate whites, but not blacks, from the literacy test by relating qualifications to whether one's grandfather had voted before a certain date. Because the provisions applied to all potential voters, the Court upheld them, although in practice the provisions had discriminatory effect on African Americans and poor whites.
, and convicted by an all-white petit jury and sentenced to be hanged.
of the Fourteenth Amendment
because blacks had been excluded from jury service following their effective disfranchisement under Mississippi's constitution of 1890. Its provisions for literacy and poll-tax qualifications essentially eliminated blacks as voters, and therefore from jury rolls, after 1892.
Williams' counsel contended that the state constitution discriminated against blacks by giving unbridled discretion to election officers, who ruled on adequate records of payment of poll taxes and qualification of electors for literacy and understanding to be registered to vote.
Although some northern Congressmen proposed stripping seats from the South's apportionment
in the United States Congress
to reflect the numbers of African Americans who were disfranchised, no action was passed. With one-party rule, white Southern Democrats had a powerful voting block which they exercised for decades, for instance, to reject any Federal legislation against lynching.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1898) is a United States Supreme Court case that reviewed provisions of the state constitution that set requirements for voter registration. The Supreme Court did not find discrimination in the state's requirements for voters to pass a literacy test
Literacy test
A literacy test, in the context of United States political history, refers to the government practice of testing the literacy of potential citizens at the federal level, and potential voters at the state level. The federal government first employed literacy tests as part of the immigration process...
and pay poll taxes, as these were applied to all voters.
In practice, the subjective nature of literacy approval by white registrars worked to drastically decrease and essentially disfranchise African American
African American
African Americans are citizens or residents of the United States who have at least partial ancestry from any of the native populations of Sub-Saharan Africa and are the direct descendants of enslaved Africans within the boundaries of the present United States...
voters.
The Court considered the new Mississippi
Mississippi
Mississippi is a U.S. state located in the Southern United States. Jackson is the state capital and largest city. The name of the state derives from the Mississippi River, which flows along its western boundary, whose name comes from the Ojibwe word misi-ziibi...
constitution passed in 1890. It upheld disfranchisement clauses which established requirements for literacy tests and poll taxes paid retroactively from one's 21st birthday as prerequisites for voter registration. A grandfather clause
Grandfather clause
Grandfather clause is a legal term used to describe a situation in which an old rule continues to apply to some existing situations, while a new rule will apply to all future situations. It is often used as a verb: to grandfather means to grant such an exemption...
effectively exempted illiterate whites, but not blacks, from the literacy test by relating qualifications to whether one's grandfather had voted before a certain date. Because the provisions applied to all potential voters, the Court upheld them, although in practice the provisions had discriminatory effect on African Americans and poor whites.
Facts
The plaintiff, Henry Williams, had been indicted for murder by an all-white grand juryGrand jury
A grand jury is a type of jury that determines whether a criminal indictment will issue. Currently, only the United States retains grand juries, although some other common law jurisdictions formerly employed them, and most other jurisdictions employ some other type of preliminary hearing...
, and convicted by an all-white petit jury and sentenced to be hanged.
Issue
Williams' counsel, Cornelius J. Jones, attacked the indictment and trial for violating the Equal Protection ClauseEqual Protection Clause
The Equal Protection Clause, part of the Fourteenth Amendment to the United States Constitution, provides that "no state shall ... deny to any person within its jurisdiction the equal protection of the laws"...
of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
because blacks had been excluded from jury service following their effective disfranchisement under Mississippi's constitution of 1890. Its provisions for literacy and poll-tax qualifications essentially eliminated blacks as voters, and therefore from jury rolls, after 1892.
Williams' counsel contended that the state constitution discriminated against blacks by giving unbridled discretion to election officers, who ruled on adequate records of payment of poll taxes and qualification of electors for literacy and understanding to be registered to vote.
Result
The U.S. Supreme Court unanimously rejected Williams' contention in a 9-0 vote, ruling that he had not shown administration of the Mississippi suffrage provision was discriminatory.Aftermath
Other Southern states created new constitutions with provisions similar to those of Mississippi's through 1908, effectively disfranchising hundreds of thousands of blacks and tens of thousands of poor whites for decades.Although some northern Congressmen proposed stripping seats from the South's apportionment
Apportionment
The legal term apportionment means distribution or allotment in proper shares.It is a term used in law in a variety of senses...
in the United States Congress
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
to reflect the numbers of African Americans who were disfranchised, no action was passed. With one-party rule, white Southern Democrats had a powerful voting block which they exercised for decades, for instance, to reject any Federal legislation against lynching.
See also
- Guinn v. United StatesGuinn v. United StatesGuinn v. United States, 238 U.S. 347 , was an important United States Supreme Court decision that dealt with provisions of state constitutions that set qualifications for voters. It found grandfather clause exemptions to literacy tests to be unconstitutional...
- List of United States Supreme Court cases, volume 170