Giles v. Harris
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| Giles v. Harris | |||||||||||||
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| Submitted February 24, 1903 Decided April 27, 1903 |
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| Holding | |||||||||||||
| The Court refused to assist African Americans in Alabama who were being systematically denied the right to vote by a scheme set up by the all-white state legislature. | |||||||||||||
| Court membership | |||||||||||||
| Chief Justice: Melville Fuller Associate Justices: John Marshall Harlan, David Josiah Brewer, Henry Billings Brown, Edward Douglass White, Rufus Wheeler Peckham, Joseph McKenna, Oliver Wendell Holmes, Jr., William R. Day |
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| Case opinions | |||||||||||||
| Majority by: Holmes Joined by: Fuller, White, Peckham, McKenna, Day Dissent by: Brewer Joined by: Brown Dissent by: Harlan |
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| Laws applied | |||||||||||||
| U.S. Const. | |||||||||||||
Giles v. Harris, 189 U.S. 475 (1903), was a controversial turn-of-the-century United States Supreme Court case in which the Court refused to assist African Americans in Alabama who were being systematically denied the right to vote by a scheme set up by the all-white state legislature.
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[edit] Facts
The plaintiff, Jackson W. Giles, sued on behalf of himself and more than five thousand other black citizens of Montgomery, Alabama, seeking to have the federal court require that the state to register them to vote. The suit was brought in response to a number of provisions in the Alabama state constitution which combined to prevent blacks from being able to register.
One of those provisions held that any person registered before January 1, 1903 (as most whites were) would thereafter be registered for life; but any person not registered at that time (as most blacks were not) would have to overcome a number of hurdles to be allowed to register. Among those hurdles was a test of the potential registrants' understanding of the duties and obligations of citizenship. This test was administered by white election officials, who conducted it in a biased manner so as to allow whites to register and exclude blacks from registering.
The District court dismissed the case on the grounds that the suit was not seeking enough in damages to bring within the jurisdiction of the federal courts. At the time, a statute was in place requiring that cases brought under federal question jurisdiction satisfy an amount-in-controversy requirement of $2000; Giles had not specified any amount of monetary damages. The plaintiff appealed the dismissal to the Supreme Court.
[edit] Issue
The Supreme Court was faced with the question of whether the federal courts had the authority to hear a case brought against government officials based on the assertion that those officials were part of a statewide conspiracy to deprive blacks of the right to vote.
[edit] Result
The Supreme Court, in an opinion written by Justice Oliver Wendell Holmes, decided to uphold the dismissal of the case, for two reasons:
- First, the Court noted that the plaintiffs were asserting that the entire registration system was unconstitutional, but the only relief they sought was to be registered. The Court suggested that it would solve nothing for the names of the plaintiffs to be added to the voter rolls while the entire voting process remained illegal.
- Second, the Court noted that under the doctrine set forth in Hans v. Louisiana, the Eleventh Amendment prohibited the plaintiff from suing the state directly in a United States federal court. Since the federal court has no power to issue an order to the state, the only way that the plaintiff's ability to vote could be enforced would be for the court to monitor the entire election process, which would be difficult in light of the overwhelming desire of the white population to prevent blacks from voting.
[edit] Dissents
Justice John Marshall Harlan and Justice David Josiah Brewer each dissented from the Court's opinion. Harlan contended that the court could have resolved the issue based on the amount-in-controversy requirement, and did not need to address the power of the federal courts to hear the merits of this suit. Harlan and Brewer both asserted that, if the question was solely one of the power of federal courts to hear this case, then the Court should find that such power indeed exists.
[edit] Aftermath
It was not until many years later that the Court would overturn Giles v. Harris in a series of cases which established that the right to vote was a fundamental right, and that federal courts have broad power to address deprivations of constitutional rights.
