KATZENBACH v. MORGAN
New York voters sought declaratory judgment in a New York federal district court to prevent compliance with Section 4(e) of the Voting Rights Act of 1965. That section provided that no person who successfully completed the sixth grade in a school accredited by the Commonwealth of Puerto Rico in which the language of instruction was other than English shall be denied the right to vote in any election because of his inability to read or write English. The plaintiffs argued that Section 4(e) prevented the enforcement of New York election laws which required an ability to read and write English as a condition of voting. A three-judge panel of the district court granted declaratory judgment and prevented enforcement of Section 4(e). It held that Congress exceeded its constitutionally designated powers in enacting Section 4(e) and usurped the powers reserved to the states under the Tenth Amendment.
Does Section 4(e) of the Voting Rights Act of 1965 exceed the scope of Congress' powers to enact legislation because it infringes on powers reserved to the states under the Tenth Amendment?
Legal provision: Voting Rights Act of 1965
No. The Supreme Court held that Section 4(e) is a proper exercise of the powers granted to Congress. With Justice William J. Brennan writing for the majority, the Court reasoned that Congress exercised its powers consistent with those afforded it by Section 5 of the Fourteenth Amendment. The Court then concluded that the Supremacy Clause prevented the enforcement of the New York English literacy requirement.