1915 жылғы «Guinn v. АҚШ» ісі және сайлау құқығындағы дискриминацияны жою

1915 U. S. Supreme Court case declaring certain voting restrictions unconstitutional

Guinn v. United States, 238 U. S. 347 (1915), was a United States Supreme Court decision that found certain grandfather clause exemptions to literacy tests for voting rights to be unconstitutional. Though these grandfather clauses were superficially race neutral, they were designed to protect the voting rights of illiterate white voters while disenfranchising black voters. The 1870 ratification of the Fifteenth Amendment to the United States Constitution barred each state from denying the right to vote on the basis of "race, color, or previous condition of servitude". In response, several Southern states, including Oklahoma, established constitutional provisions designed to effectively disenfranchise African Americans (including but not limited to American Descendants of Slavery (ADOS)) voters without explicitly violating the Fifteenth Amendment. In his majority opinion, Chief Justice Edward Douglass White held that Oklahoma's grandfather clause was "repugnant to the Fifteenth Amendment and therefore null and void". The decision had little immediate impact, as Southern legislatures found other methods to disenfranchise Americans of Color.

The 15th Amendment to the Constitution of the United States provides the right to not be discriminated against while voting on the basis of race, color, or previous servitude. In the view of some, the Grandfather Clause in the Oklahoma Constitution was void of racial discrimination since it looked at relatives prior to 1866 and not 1871, creating a loophole that allowed discrimination.

Grandfather clauses were first instituted as a means of allowing whites to vote while simultaneously disenfranchising blacks. The grandfather clause in Guinn v. United States involved requirement that a citizen must pass a literacy test in order to register to vote. At the time, many poor whites in the South were illiterate and would lose their voting rights if contingent upon passing a literacy test. The grandfather clauses were introduced since very few poor whites did not have a grandfather who had been able to vote. These clauses typically allowed poor, illiterate whites to register to vote if they had been able to vote before 1867 or if their ancestors could have voted then, creating a loophole. The laws had time limits, which were used to try to get as many white voters registered as possible before the laws were challenged in court. The modern expression 'grandfathered in', despite its links with this racial history, is not generally associated with it.

The case was argued before the Supreme Court on October 17, 1913. It represented the second appearance before the Court of John W. Davis as United States Solicitor General and the first case in which the National Association for the Advancement of Colored People (NAACP) filed a brief. After the case was argued, the Court ruled that the grandfather clause of the Constitution of Oklahoma was created and intended to exclude as many illiterate black people as possible and include as many illiterate whites as possible. The number of black citizens allowed to vote under the clause approximately equals the number of white citizens barred from voting. This is undoubtedly proof of discrimination and differences in classifying whites and blacks into two classes of illiterates. Therefore, the entire amendment regarding illiteracy in voters is wholly unconstitutional, violating the 15th Amendment. The clause was implemented as a way to try to avoid violating the 15th Amendment while still disenfranchising black voters. The previous conditions of servitude based on the race or skin color of people rendered them incapable of gaining literacy or meeting the ambiguously formed loopholes within said clause. The convictions of Guinn and Beal were upheld.

The Supreme Court handed down its decision in Guinn v. United States together with Myers v. Anderson, which concerned a grandfather clause in the Maryland constitution. In its decision published on June 21, 1915, the Court found "the grandfather clauses in the Maryland and Oklahoma constitutions to be repugnant to the Fifteenth Amendment and therefore null and void". In his majority opinion, Chief Justice Edward Douglass White held that the grandfather clause was clearly designed to interfere with the voting rights protections of the Fifteenth Amendment even though it was racially neutral on its face.