The Waite Court (1874–88)

Voting Rights

The Waite Court refused to enforce the Fifteenth Amendment in what decision?

The Waite Court ruled 8–1 in United States v. Reese (1876) that federal charges against Kentucky election official Hiram Reese should be dismissed even though Reese had prevented African American William Garner from voting. Reese would not allow Garner to vote unless Garner showed his receipt for paying a poll tax, but apparently other election officials would not allow Garner to pay the poll tax. The Court had a clear opportunity to enforce the Fifteenth Amendment, which prohibited the denial of the right to vote based on race. The Court, however, determined that one section of the Kentucky statute went too far by prohibiting actions by election officials that had nothing to do with race. The net effect of the decision was that it embolded state officials, particularly in Southern states, to evade the requirements of the Fifteenth Amendment by couching their objections to would-be African American voters in terms of poll taxes and literary requirements.


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