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Lane v. Wilson

307 U.S. 268 (1939)

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Lane v. Wilson

United States Supreme Court

307 U.S. 268 (1939)

Facts

Prior to 1915, Oklahoma required voters to undergo a literacy test before being allowed to register to vote. The policy included a grandfather clause which largely allowed White voters to be excused from taking the literacy test. In 1915, in Guinn v. United States, 238 U.S. 347 (1915), the United States Supreme Court declared the Oklahoma literacy test unconstitutional. In response, Oklahoma enacted a new law that gave all newly eligible voters a 12-day window to register to vote. Those who did not register in the window were forever barred from voting. Again, an exception applied for those who were registered to vote in 1914, before the literacy test was struck down. In effect, the registration window kept only Black voters from voting. In 1934, Lane, a Black man living in Oklahoma, was denied the opportunity to register to vote. Lane filed suit, alleging that prohibiting him from registering was unconstitutional. The district court entered a directed verdict against Lane. The United States Court of Appeals for the Tenth Circuit affirmed the district court’s judgment. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Frankfurter, J.)

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