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South Carolina v. Katzenbach, 383 U.S. 301 (1966), is a United States Supreme Court case in which the Court rejected a challenge by the state of South Carolina to the preclearance provisions of the Voting Rights Act of 1965, which required that some states submit changes in election districts to the Attorney General of the United States (at the time, Nicholas Katzenbach).

Background
The Voting Rights Act required states to make adjustments to their voting and registration systems if the state employed a literacy test and if the voter turnout or registration was less than fifty percent by November 1, 1964. This was known as the preclearance requirement and affected mostly southern states, making them seek approval from the U.S. District Court for any changes in the voting system.

In South Carolina, the state attorney general, Daniel R. McLeod filed a complaint directly with the Supreme Court attacking the constitutionality of the act and asking for an injunction against enforcement by the attorney general of the United States, Nicholas Katzenbach. McLeod challenged the Voting Rights Act as an unconstitutional encroachment on states’ rights, as a violation of equality between the states, and as an illegal bill of attainder which is a legislative punishment enforced without due process of law.

South Carolina was joined on its attack on the Voting Rights Act by other southern states. Meanwhile, twenty states filed in support of the act’s provisions and powers mainly consisted of northern and western states. The case took on an even wider significance than normal in a state challenge to a new federal law.

The decision represents a rare instance of the Supreme Court exercising its original jurisdiction, as the case was filed directly in the Supreme Court by the state of South Carolina, rather than being appealed from a lower court. The court intentionally heard the case prior to the 1966 elections.

Opinion of the Court
In his opinion for the Court, Chief Justice Earl Warren wrote that the Voting Rights Act was a valid exercise of Congress' power under the enforcement clause of the Fifteenth Amendment to the United States Constitution.

My Contribution

Warren cited the enforcement clause of the 15th Amendment which gave congress full powers to stop discrimination in regards to voting. He also stated that the Voting Rights Act was necessary to "remedy the evil of racism". Additionally, the historical record showed that the 15th Amendment was not strong enough on its own since voter discrimination had continued. The Voting Rights Act provide sterner and enforceable measures to ensure equal voting opportunities to all citizens.

The only dissent in the ruling came from Justice Hugo L. Black who opposed legislation because he felt exceeded the textual reach of the constitution. In his dissent he explained, “There is no reason to read into the Constitution meanings it did not have when it was adopted and which have not been put into place.”  While he would have sustained most of the law, he would have struck down the Section 5 pre-clearance provisions:

Impact- My Contribution
Through the courts majority decision, the Voting Rights Act was upheld and able to be implemented without any barriers or changes. Southern states were required to change their voting methods to allow African American to register without provisions. According to Indiana University Maurer School of Law professor Luis Fuentes-Rohwer, the case served as an example of a firm interpretation of the 15th Amendment, which granted Congress "full remedial powers" to prevent any racial discrimination. Fuentes-Roher also stated that the case was also an example of the Supreme Court giving more power to Congress by allowing them to create legislation on a topic usually reserved to the States. Opponents of the ruling cite this as an example of judicial activism on steroids, implying this was an overreach of the Supreme Court's powers and decided by the judges personal beliefs instead of the law.

This ruling was a massive win for the Civil Rights Movement, allowing for over 800,000 African Americans to register to vote between 1964 and 1967. The success of the Voting Rights Act allowed President Johnson to continue with the civil rights reform, including the Fair Housing Act. This act provided equal housing opportunities regardless of race, religion, or nationality. This case was also used as precedent in other judicial challenges to the Voting Rights Act such as Allen v. State Board of Elections and Beer v. United States.

The significance of South Carolina v. Katzenbach diminished in 2013 with the decision of Shelby County v. Holder. The Supreme Court struck down provisions in the Voting Rights Act 5-4 because it was based on decades old data, making it no longer applicable.