Giles v. Harris
Encyclopedia
Giles v. Harris, 189 U.S. 475
(1903), was an early 20th century United States Supreme Court
case in which the Court upheld a state constitution's requirements for voter registration and qualifications. Although the plaintiff accused the state of discriminating in practice against black citizens, the Court found that the requirements applied to all citizens and refused to undertake overseeing the state's process.
Booker T. Washington
, although he was publicly known for an accommodationist stand for black advancement, secretly arranged for funding and representation for Jackson W. Giles in this lawsuit and the ensuing Giles v. Teasley (1904). He worked extensively behind the scenes to direct and raise funds for other lawsuits and segregation challenges as well.
, Jackson W. Giles, sued on behalf of more than five thousand black citizens of Montgomery
, Alabama
and himself in seeking to have the federal court
require the state to register them to vote. The suit was brought in response to a number of provisions in the Alabama state constitution which combined to prevent blacks from being able to register. Giles was literate and had voted in Montgomery from 1871 to 1901.
One of the new provisions held that any person registered before January 1, 1903 (as most whites were) would thereafter be registered for life; but any person not registered at that time (as most blacks were not) would have to overcome a number of hurdles to be allowed to register. Among those hurdles was a test of the potential registrant's understanding of the duties and obligations of citizenship. This test was administered by white election officials, who conducted it in a subjective manner that resulted in most whites' being approved to register and most blacks being rejected from registering.
The U.S. District court
dismissed the case on the grounds that the suit was not seeking enough in damages to bring it within the jurisdiction
of the federal courts. At the time, a statute was in place requiring that cases brought under federal question jurisdiction
satisfy an amount-in-controversy requirement of $2000. Giles had not specified any amount of monetary damages. The plaintiff appealed the dismissal to the U.S. Supreme Court.
, decided to uphold the dismissal of the case, for two reasons:
and Justice David Josiah Brewer
each dissented from the Court's opinion. Harlan contended that the court could have resolved the issue based on the amount-in-controversy requirement, and did not need to address the power of the Federal courts to hear the merits of this suit. Harlan and Brewer both asserted that, if the question was solely one of the power of Federal courts to hear this case, then the Court should find that such power indeed exists.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1903), was an early 20th century United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case in which the Court upheld a state constitution's requirements for voter registration and qualifications. Although the plaintiff accused the state of discriminating in practice against black citizens, the Court found that the requirements applied to all citizens and refused to undertake overseeing the state's process.
Booker T. Washington
Booker T. Washington
Booker Taliaferro Washington was an American educator, author, orator, and political leader. He was the dominant figure in the African-American community in the United States from 1890 to 1915...
, although he was publicly known for an accommodationist stand for black advancement, secretly arranged for funding and representation for Jackson W. Giles in this lawsuit and the ensuing Giles v. Teasley (1904). He worked extensively behind the scenes to direct and raise funds for other lawsuits and segregation challenges as well.
Facts
The plaintiffPlaintiff
A plaintiff , also known as a claimant or complainant, is the term used in some jurisdictions for the party who initiates a lawsuit before a court...
, Jackson W. Giles, sued on behalf of more than five thousand black citizens of Montgomery
Montgomery, Alabama
Montgomery is the capital of the U.S. state of Alabama, and is the county seat of Montgomery County. It is located on the Alabama River southeast of the center of the state, in the Gulf Coastal Plain. As of the 2010 census, Montgomery had a population of 205,764 making it the second-largest city...
, Alabama
Alabama
Alabama is a state located in the southeastern region of the United States. It is bordered by Tennessee to the north, Georgia to the east, Florida and the Gulf of Mexico to the south, and Mississippi to the west. Alabama ranks 30th in total land area and ranks second in the size of its inland...
and himself in seeking to have the federal court
United States district court
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States...
require the state to register them to vote. The suit was brought in response to a number of provisions in the Alabama state constitution which combined to prevent blacks from being able to register. Giles was literate and had voted in Montgomery from 1871 to 1901.
One of the new provisions held that any person registered before January 1, 1903 (as most whites were) would thereafter be registered for life; but any person not registered at that time (as most blacks were not) would have to overcome a number of hurdles to be allowed to register. Among those hurdles was a test of the potential registrant's understanding of the duties and obligations of citizenship. This test was administered by white election officials, who conducted it in a subjective manner that resulted in most whites' being approved to register and most blacks being rejected from registering.
The U.S. District court
United States district court
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States...
dismissed the case on the grounds that the suit was not seeking enough in damages to bring it within the jurisdiction
Jurisdiction
Jurisdiction is the practical authority granted to a formally constituted legal body or to a political leader to deal with and make pronouncements on legal matters and, by implication, to administer justice within a defined area of responsibility...
of the federal courts. At the time, a statute was in place requiring that cases brought under federal question jurisdiction
Federal question jurisdiction
Federal question jurisdiction is a term used in the United States law of civil procedure to refer to the situation in which a United States federal court has subject-matter jurisdiction to hear a civil case because the plaintiff has alleged a violation of the Constitution or law of the...
satisfy an amount-in-controversy requirement of $2000. Giles had not specified any amount of monetary damages. The plaintiff appealed the dismissal to the U.S. Supreme Court.
Issue
The Supreme Court was faced with the question of whether the Federal courts had the authority to hear a case brought against government officials based on the assertion that those officials were part of a statewide conspiracy to deprive blacks of the right to vote.Result
The Supreme Court, in an opinion written by Justice Oliver Wendell HolmesOliver Wendell Holmes, Jr.
Oliver Wendell Holmes, Jr. was an American jurist who served as an Associate Justice of the Supreme Court of the United States from 1902 to 1932...
, decided to uphold the dismissal of the case, for two reasons:
- First, the Court noted that the plaintiffs were asserting that the entire registration system was unconstitutional, but the only relief they sought was to be registered. The Court suggested that it would solve nothing for the names of the plaintiffs to be added to the voter rolls while the entire voting process remained illegal.
- Second, the Court noted that under the doctrine set forth in Hans v. LouisianaHans v. LouisianaHans v. Louisiana, , was a decision of the United States Supreme Court determining that the Eleventh Amendment prohibits the citizen of a U.S. state to sue that state in a federal court.-Facts:The plaintiff, Hans, was a citizen of the state of Louisiana...
, the Eleventh Amendment prohibited the plaintiff from suing the state directly in a United States federal court. Since the federal court has no power to issue an order to the state, the only way that the plaintiff's ability to vote could be enforced would be for the court to monitor the entire election process, which would be difficult in light of the overwhelming desire of the white population to prevent blacks from voting.
Dissents
Justice John Marshall HarlanJohn Marshall Harlan
John Marshall Harlan was a Kentucky lawyer and politician who served as an associate justice on the Supreme Court. He is most notable as the lone dissenter in the Civil Rights Cases , and Plessy v...
and Justice David Josiah Brewer
David Josiah Brewer
David Josiah Brewer was an American jurist and an Associate Justice of the U.S. Supreme Court for 20 years.-Early life:...
each dissented from the Court's opinion. Harlan contended that the court could have resolved the issue based on the amount-in-controversy requirement, and did not need to address the power of the Federal courts to hear the merits of this suit. Harlan and Brewer both asserted that, if the question was solely one of the power of Federal courts to hear this case, then the Court should find that such power indeed exists.
Aftermath
In Giles v. Teasley, Jackson Giles sought to meet some of the Court's grounds for its rulings, but his challenge was rejected. It was not until many years later that the Court would overturn Giles v. Harris in a series of cases which established that the right to vote was protected by the equal protection clause of the 14th Amendment, and that federal courts have broad power to address deprivations of constitutional rights of citizens within states. After Federal civil rights legislation was passed in the mid-1960s, it did in fact take several more years of Federal court oversight and Federal intervention and monitoring to ensure that African Americans were allowed to register to vote in the South. When Giles v. Harris was brought to the Supreme Court, some members of the Court (and the Executive Branch) did not conceive of exercising such powers years after Reconstruction had ended. However, the Legislative Branch had exercised such power up until the time of Giles v. Harris, as the House Elections Committee repeatedly refused to seat members reported elected by their states when it felt that the voting or registration process had been compromised. Since the excluded members were inevitably Democrats, partisan politics could play a role in these decisions; certainly such members were unseated only when Republicans held the majority in the House. After the decision, the Legislative Branch as well ceased unseating members because of these concerns.Further reading
- Brenner, Samuel, "'Airbrushed out of the Constitutional Canon': The Evolving Understanding of Giles v. Harris, 1903–1925," Michigan Law Review, 107 (March 2009), 853–79.