KATZENBACH V. MORGAN
384 U.S. 641 (1966)
NATURE OF THE CASE: This is a challenge to the constitutionality of a federal statute
Section 4(e) of the Federal Voting Rights Act.
FACTS: A New York statute required that anyone who wished to register to vote had to be
able to read and write English. In 1965, Congress passed a Voting Rights Act that provided
that a person who had at least a sixth grade education in Puerto Rico in Spanish was
eligible to vote. Morgan (P) was a registered voter in the city of New York. He challenged
this federal statute as opposing the state statute. He claimed that several hundred thousand
Puerto Rican immigrants would be denied voting by the state law, but reinstated by the
federal law. New York's Attorney General argued that the federal legislation could take
precedence over the state statute only if the state violated the fourteenth amendment. He
also claimed that the federal legislation violated the fourteenth amendment since it
discriminated between non-English speaking people in Puerto Rico and non-English speaking
people from other countries. A three-judge district court was designated. The court granted
the declaratory and injunctive relief appellees sought. The court held that, in enacting
4(e), Congress exceeded the powers granted to it by the Constitution, and therefore usurped
powers reserved to the States by the Tenth Amendment. The United States Attorney General,
Katzenbach (D), appealed.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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