Guinn v. United States: A First Step to Voter Rights for African Americans

Protester holding sign demanding the protection of voting rights
50th Anniversary of the March on Washington. Bill Clark / Getty Images

Guinn v. United States was a United States Supreme Court case decided in 1915, dealing with the constitutionality of voter qualification provisions in state constitutions. Specifically, the court found residency-based “grandfather clause” exemptions to voter literacy tests—but not the tests themselves—to be unconstitutional.

Literacy tests were used in several Southern states between the 1890s and 1960s as a way of preventing African Americans from voting. The unanimous decision in Guinn v. United States marked the first time the Supreme Court struck down a state law disenfranchising African Americans. 

Fast Facts: Guinn v. United States

  • Case Argued: Oct. 17, 1913
  • Decision Issued: June 21, 1915
  • Petitioners: Frank Guinn and J. J. Beal, Oklahoma election officials
  • Respondent: United States
  • Key Questions: Did Oklahoma’s grandfather clause, in singling out black Americans as being required to take a voter literacy test, violate the U.S. Constitution? Did Oklahoma’s literacy test clause—without the grandfather clause—violate the U.S. Constitution?
  • Majority Decision: Justices White, McKenna, Holmes, Day, Hughes, Van Devanter, Lamar, Pitney
  • Dissenting: None, but Justice McReynolds took no part in the consideration or decision of the case.
  • Ruling: The Supreme Court ruled that residency-based “grandfather clause” exemptions to voter literacy tests—but not the tests themselves—were unconstitutional.

Facts of the Case

Shortly after it was admitted into the Union in 1907, the state of Oklahoma passed an amendment to its constitution requiring that citizens pass a literacy test before being allowed to vote. However, the state’s Voter Registration Act of 1910 contained a clause allowing voters whose grandfathers had either been eligible to vote before January 1, 1866, had been residents of “some foreign nation,” or had been soldiers, to vote without taking the test. Rarely affecting white voters, the clause disenfranchised many black voters because their grandfathers had been slaves before 1866 and were thus ineligible to vote. 

As applied in most states, the literacy tests were highly subjective. Questions were confusingly worded and often had several possible correct answers. In addition, the tests were graded by white election officials who had been trained to discriminate against black voters. In one instance, for example, election officials rejected a black college graduate even though there was not “the slightest room for doubt as to whether” he was entitled to vote, concluded the U.S. Circuit Court.

After the 1910 November midterm election, Oklahoma election officials Frank Guinn and J.J. Beal were charged in federal court with conspiring to fraudulently disenfranchise black voters, in violation of the Fifteenth Amendment. In 1911, Guinn and Beal were convicted and appealed to the Supreme Court.

Constitutional Issues

While the Civil Rights Act of 1866 had guaranteed U.S. citizenship without regard to race, color, or previous condition of slavery or involuntary servitude, it did not address the voting rights of former slaves. To bolster the Thirteenth and Fourteenth Amendments of the Reconstruction-era, the Fifteenth Amendment, ratified on February 3, 1870, prohibited the federal government and the states from denying any citizen the right to vote based on their race, color, or previous condition of servitude.

The Supreme Court faced two related Constitutional questions. First, did Oklahoma’s grandfather clause, in singling out black Americans as being required to take the literacy test, violate the U.S. Constitution? Second, did Oklahoma’s literacy test clause—without the grandfather clause—violate the U.S. Constitution?

The Arguments

The state of Oklahoma argued that the 1907 amendment to its state constitution was validly passed and clearly within the powers of the states granted by the Tenth Amendment. The Tenth Amendment reserves all powers not specifically granted to the U.S. government in Article I, Section 8 of the Constitution to the states or to the people.

Attorneys for the U.S. government chose to argue only against the constitutionality of the “grandfather clause” itself while conceding that literacy tests, if written and administered to be racially neutral, were acceptable.

Majority Opinion

In its unanimous opinion, delivered by Chief Justice C.J. White on June 21, 1915, the Supreme Court ruled that Oklahoma’s grandfather clause—having been written in a way to serve “no rational purpose” other than to deny African American citizens the right to vote—violated the Fifteenth Amendment to the U.S. Constitution. The convictions of Oklahoma election officials Frank Guinn and J.J. Beal were thus upheld.

However, since the government had previously conceded the point, Justice White wrote that, “No time need be spent on the question of the validity of the literacy test, considered alone, since, as we have seen, its establishment was but the exercise by the State of a lawful power vested in it not subject to our supervision, and, indeed, its validity is admitted.”

Dissenting Opinion

As the court’s decision was unanimous, with only Justice James Clark McReynolds not taking part in the case, no dissenting opinion was issued.

The Impact

In overturning Oklahoma’s grandfather clause, but upholding its right to require pre-voting literacy tests, the Supreme Court confirmed the historic rights of the states to establish voter qualifications as long as they did not otherwise violate the U.S. Constitution. While it was a symbolic legal victory for African American voting rights, the Guinn ruling fell far short of immediately enfranchising black Southern citizens.

At the time it was issued, the court’s ruling also nullified similar voter qualification provisions in the constitutions of Alabama, Georgia, Louisiana, North Carolina, and Virginia. While they could no longer apply grandfather clauses, their state legislatures enacted poll taxes and other means of restricting black voter registration. Even after the Twenty-Fourth Amendment prohibited the use of poll taxes in federal elections, five states continued to impose them in state elections. Not until 1966 did the U.S. Supreme Court declare poll taxes in state elections unconstitutional. 

In final analysis, Guinn vs. United States decided in 1915, was a small, but a significant first legal step in the Civil Rights Movement toward racial equality in the United States. It was not until passage of the Voting Rights Act of 1965 that all remaining legal barriers denying black Americans the right to vote under the Fifteenth Amendment—enacted nearly a century earlier—were finally outlawed.

Sources and Further Reference