South Carolina v. Katzenbach

Summary

The Supreme Court considered South Carolina's challenge to selected provisions of the Voting Rights Act of 1965. The Court held that the provisions properly before it were appropriate measures under Congress's enforcement authority under the Fifteenth Amendment and were consistent with the Constitution, denying South Carolina's request for an injunction.

Holdings

1. Congress may use any rational means appropriate to effectuate the Fifteenth Amendment's prohibition against racial discrimination in voting, including specific remedies directed at particular jurisdictions.
2. The Section 4(b) coverage formula was a rational and permissible means of identifying jurisdictions subject to the Act's special remedies.
3. The Act's temporary suspension of literacy tests and similar voting devices in covered jurisdictions was a constitutional and appropriate remedy.
4. Section 5's suspension of new voting qualifications, standards, practices, and procedures pending federal review was a constitutional exercise of Congress's Fifteenth Amendment enforcement power and did not authorize advisory opinions.
5. The Act's authorization for federal examiners to register qualified voters in covered political subdivisions, subject to an expedited challenge procedure, was constitutional.
6. South Carolina could not invoke the Due Process Clause, Bill of Attainder Clause, or separation-of-powers principle as protections applicable to a State against the Federal Government in this case; the objections were considered only as aspects of whether Congress acted appropriately under the Fifteenth Amendment.

Questions Presented

1. Whether Congress's enforcement provisions under Section 2 of the Fifteenth Amendment were limited to prohibiting discrimination in general terms or could include specific, preventive, and geographically targeted remedies.
2. Whether the Voting Rights Act's Section 4 coverage formula was an appropriate exercise of Congress's Fifteenth Amendment enforcement power.
3. Whether the Act's suspension of literacy tests and similar voting devices was constitutional.
4. Whether Section 5's suspension of new voting rules pending federal review was constitutional and violated Article III by authorizing advisory opinions.
5. Whether the federal-examiner and voter-listing provisions were constitutional, including challenges based on due process, separation of powers, and the absence of judicial review of administrative findings.
6. Whether the Act's limitation of certain litigation to the United States District Court for the District of Columbia violated constitutional principles.
7. Whether South Carolina could invoke the Due Process Clause, Bill of Attainder Clause, and separation-of-powers principles against the Federal Government in its capacity as a State.

Disposition

dismissed