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Oregon v. Mitchell

Citations: 27 L. Ed. 2d 272; 91 S. Ct. 260; 400 U.S. 112; 1970 U.S. LEXIS 1Docket: 43 ORIG

Court: Supreme Court of the United States; December 21, 1970; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

The case involves challenges by several states to the Voting Rights Act Amendments of 1970, which aimed to lower the voting age to 18, prohibit discriminatory literacy tests, and standardize residency requirements for federal elections. The Court examined Congress's authority under Article I, Section 4 of the Constitution, which allows Congress to regulate federal elections, and the Enforcement Clause of the Civil War Amendments, which addresses racial discrimination in voting. The Court upheld Congress's authority to set the voting age for federal elections but not for state and local elections. It also affirmed the prohibition of literacy tests that discriminate based on race, and allowed Congress to manage absentee voting and residency requirements for federal elections. The decision emphasized the division of power between state and federal governments, confirming federal supremacy in regulating national elections while acknowledging state control over local elections. The Court applied the severability clause to maintain valid provisions of the Act and highlighted the historical context of Congressional oversight in ensuring equitable representation. The ruling underscores the balance between federal authority and state governance in electoral matters, respecting the constitutional framework established by the Framers and modified by amendments post-Civil War.

Legal Issues Addressed

Congressional Authority Over Federal Elections

Application: The Court determined that Congress has the authority to set the voting age for federal elections and regulate federal election procedures.

Reasoning: The Court concluded that Congress has the authority to set the voting age for federal elections but not for state and local elections.

Prohibition of Discriminatory Literacy Tests

Application: The Court upheld Congress's power to prohibit literacy tests that discriminate on the basis of race in both federal and state elections.

Reasoning: It also ruled that Congress can prohibit discriminatory literacy tests in both state and federal elections, with all Justices concurring on this point.

Severability of Legislative Provisions

Application: The Court applied the severability principle, allowing valid provisions of the Voting Rights Act Amendments to remain effective despite invalid provisions.

Reasoning: The Voting Rights Act Amendments of 1970 included a severability provision, allowing parts of the Act to remain in effect if others are deemed invalid.

State Authority in Election Regulation

Application: The Court recognized state authority over setting voter qualifications for state and local elections, except where overridden by federal law.

Reasoning: While states have the power to legislate on national elections, Congress retains ultimate supervisory authority.

Supremacy of Federal Law Over State Law

Application: The Court confirmed that federal law overrides conflicting state laws, such as state literacy test requirements.

Reasoning: The author asserts that the federal ban is constitutional under the Enforcement Clause of the Fifteenth Amendment and overrides Arizona's laws due to the Supremacy Clause.