''Ex parte Yarbrough'' (also known as the ''Ku Klux Cases''), 110

U.S. The United States of America (USA), also known as the United States (U.S.) or America, is a country primarily located in North America. It is a federal republic of 50 states and a federal capital district, Washington, D.C. The 48 contiguous ...

651 (1884), was a decision of the

Supreme Court of the United States The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all Federal tribunals in the United States, U.S. federal court cases, and over Stat ...

involving Congress's power to punish individuals who interfere with the right to vote in federal elections. The Court sustained the convictions of Jasper Yarbrough and seven others, who had been found guilty of beating and injuring an African-American man to prevent him from voting. The decision marked one of the few times that the post-

Reconstruction Reconstruction may refer to: Politics, history, and sociology *Reconstruction (law), the transfer of a company's (or several companies') business to a new company *''Perestroika'' (Russian for "reconstruction"), a late 20th century Soviet Union ...

Court upheld Congress's ability to protect civil rights.

Background

The Fifteenth Amendment to the U.S. Constitution states that "the right of citizens of the United States to vote shall not be denied or abridged by the United States or by any State on account of race, color, or previous condition of servitude", and it gives Congress the ability to enforce that right "by appropriate legislation". Congress passed several laws to enforce the Fifteenth Amendment, but the federal judiciary was reluctant to protect former slaves' right to vote. In ''

United States v. Reese ''United States v. Reese'', 92 U.S. 214 (1876), was a voting rights case in which the United States Supreme Court narrowly construed the Fifteenth Amendment to the United States Constitution The Fifteenth Amendment (Amendment XV) to the Uni ...

'' (1876), the Supreme Court struck down several sections of the

Enforcement Act of 1870 The Enforcement Act of 1870, also known as the Civil Rights Act of 1870 or First Ku Klux Klan Act, or Force Act (41st Congress, Sess. 2, ch. 114, , enacted May 31, 1870, effective 1871), is a United States federal law that empowers the Presiden ...

that outlawed racial discrimination on the part of local elections officials. The Court invalidated an anti-discrimination law in the ''

Civil Rights Cases The ''Civil Rights Cases'', 109 U.S. 3 (1883), were a group of five landmark cases in which the Supreme Court of the United States held that the Thirteenth and Fourteenth Amendments did not empower Congress to outlaw racial discrimination by ...

'' (1883), and it voided Section 5519 of the

Revised Statutes Revised Statutes is a term used in some common law jurisdictions for a collection of statutes that have been revised to incorporate amendments, repeals and consolidations. It is not a change to the law, but designed to make the body of statutes m ...

(formerly Section 2 of the Ku Klux Act of 1871), which prevented individuals from interfering with legally protected rights, in '' United States v. Harris'' (1883). Jasper Yarbrough and seven fellow members of the

Ku Klux Klan The Ku Klux Klan (), commonly shortened to KKK or Klan, is an American Protestant-led Christian terrorism, Christian extremist, white supremacist, Right-wing terrorism, far-right hate group. It was founded in 1865 during Reconstruction era, ...

beat and injured Berry Saunders, an African-American man, in order to keep him from casting a vote in a Georgia congressional election. They were charged with violating two provisions of federal law: Sections 5508 (derived from Section 6 of the

) and 5520 (derived from Section 2 of the Ku Klux Act of 1871) of the Revised Statutes, which prevented individuals from conspiring to deprive others of their constitutional rights and their right to vote in federal elections. The defendants were tried and convicted in the Circuit Court for the Northern District of Georgia, and five were sentenced to two years' imprisonment each. They sought a writ of

habeas corpus ''Habeas corpus'' (; from Medieval Latin, ) is a legal procedure invoking the jurisdiction of a court to review the unlawful detention or imprisonment of an individual, and request the individual's custodian (usually a prison official) to ...

, arguing that Congress's power to regulate elections did not permit it to regulate the conduct of individuals. The Supreme Court heard arguments in the case on January 23 and 24, 1884.

Decision

The Court rendered its decision on March 3, 1884. In a unanimous opinion by Justice Samuel F. Miller, the justices rejected the appeal and upheld Yarbrough's conviction. Miller interpreted the Fifteenth Amendment broadly, arguing that it directly conferred a right to vote in federal elections. Once an individual met the qualifications to vote imposed by state law, the Court concluded, he had a right to vote, and Congress could exercise its power "to protect the citizen in the exercise of rights conferred by the Constitution of the United States essential to the healthy organization of the government itself". Miller cited Article I, Section 4 of the Constitution, which authorizes Congress to regulate federal elections. In closing, he wrote:

Analysis and legacy

The Court in ''Yarbrough'' "fused the Fifteenth Amendment and article I, section 4 to come up with a bold, highly nationalist approach to black voting rights", in the words of the scholar Richard M. Valelly. According to the political scientist

Rogers Smith Rogers M. Smith (born September 20, 1953) is an American political scientist and author noted for his research and writing on American constitutional and political development and political thought, with a focus on issues of citizenship and r ...

, it was "the one Supreme Court decision markedly favorable to black voting rights" in the post-Reconstruction era. In subsequent years, the Court's interpretation of the Fifteenth Amendment continued to change: in a decision in '' James v. Bowman'' (1903) that did not mention ''Yarbrough'', it struck down by a 6–2 vote another provision of the

Enforcement Acts The Enforcement Acts were three bills that were passed by the United States Congress between 1870 and 1871. They were criminal codes that protected African Americans’ right to vote, to hold office, to serve on juries, and receive equal protect ...

on the grounds that it was not authorized by the Fifteenth Amendment. ''Yarbrough'' has received limited attention from scholars, although recent analyses have emphasized it more strongly. The decision played a prominent role in the voter registration campaign of the 1960s, and Sefton writes that it "forms part of the philosophical foundation of the constitutional law of all civil rights". According to the scholar William Gillette, Miller's "remarkable" opinion "began to build the judicial foundation for the civil rights movement".

References

External links

*{{Caselaw source, case=''Ex parte Yarbrough'', {{ussc, 110, 651, 1884, el=no, justia=https://supreme.justia.com/cases/federal/us/110/651/, cornell=https://www.law.cornell.edu/supremecourt/text/110/651, other_source1=Casetext, other_url1=https://casetext.com/case/ex-parte-yarbrough, loc=https://tile.loc.gov/storage-services/service/ll/usrep/usrep110/usrep110651/usrep110651.pdf, courtlistener=https://www.courtlistener.com/opinion/91064/ex-parte-yarbrough/ United States Supreme Court cases United States Supreme Court cases of the Waite Court 1884 in United States case law United States Fifteenth Amendment case law Legal history of Georgia (U.S. state) History of voting rights in the United States