Minor v. Happersett
Encyclopedia
Minor v. Happersett, , was a United States Supreme Court
case appealed from the Supreme Court of Missouri
concerning the Missouri
law which ordained "Every male
citizen of the United States shall be entitled to vote."
Virginia Minor
, a leader of the women's suffrage
movement in Missouri
, alleged that the refusal of Reese Happersett, a Missouri state registrar, to allow her to register to vote was an infringement of her civil rights
under the Fourteenth Amendment
.
upheld the Missouri voting legislation saying that the limitation of suffrage to male citizens was not an infringement of Minor's rights under the Fourteenth Amendment.
The United States Supreme Court affirmed and upheld the lower court's ruling on the basis that the Fourteenth Amendment
does not add to the privileges or immunities
of a citizen and that, historically, "citizen" and "eligible voter" have not been synonymous. Since the United States Constitution
did not provide suffrage for women, the Fourteenth Amendment did not confer that right. The court's decision had nothing to do with whether women were considered persons under the Fourteenth Amendment; the court ruled that they were clearly persons and citizens. It rested solely on the lack of provisions within the Constitution for women's suffrage.
does not confer the right to vote. However, as the decision relates to women's suffrage in particular, it is no longer applicable because of the Nineteenth Amendment
.
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 appealed from the Supreme Court of Missouri
Supreme Court of Missouri
The Supreme Court of Missouri is the highest court in the state of Missouri. It was established in 1820, and is located in Jefferson City, Missouri. Missouri voters have approved changes in the state's constitution to give the Supreme Court exclusive jurisdiction- the sole legal power to hear -...
concerning the Missouri
Missouri
Missouri is a US state located in the Midwestern United States, bordered by Iowa, Illinois, Kentucky, Tennessee, Arkansas, Oklahoma, Kansas and Nebraska. With a 2010 population of 5,988,927, Missouri is the 18th most populous state in the nation and the fifth most populous in the Midwest. It...
law which ordained "Every male
Male
Male refers to the biological sex of an organism, or part of an organism, which produces small mobile gametes, called spermatozoa. Each spermatozoon can fuse with a larger female gamete or ovum, in the process of fertilization...
citizen of the United States shall be entitled to vote."
Virginia Minor
Virginia Minor
Virginia Louisa Minor was an American women's suffrage activist. She is best remembered as the plaintiff in Minor v...
, a leader of the women's suffrage
Women's suffrage
Women's suffrage or woman suffrage is the right of women to vote and to run for office. The expression is also used for the economic and political reform movement aimed at extending these rights to women and without any restrictions or qualifications such as property ownership, payment of tax, or...
movement in Missouri
Missouri
Missouri is a US state located in the Midwestern United States, bordered by Iowa, Illinois, Kentucky, Tennessee, Arkansas, Oklahoma, Kansas and Nebraska. With a 2010 population of 5,988,927, Missouri is the 18th most populous state in the nation and the fifth most populous in the Midwest. It...
, alleged that the refusal of Reese Happersett, a Missouri state registrar, to allow her to register to vote was an infringement of her civil rights
Civil rights
Civil and political rights are a class of rights that protect individuals' freedom from unwarranted infringement by governments and private organizations, and ensure one's ability to participate in the civil and political life of the state without discrimination or repression.Civil rights include...
under the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
.
Decision
The Supreme Court of MissouriSupreme Court of Missouri
The Supreme Court of Missouri is the highest court in the state of Missouri. It was established in 1820, and is located in Jefferson City, Missouri. Missouri voters have approved changes in the state's constitution to give the Supreme Court exclusive jurisdiction- the sole legal power to hear -...
upheld the Missouri voting legislation saying that the limitation of suffrage to male citizens was not an infringement of Minor's rights under the Fourteenth Amendment.
The United States Supreme Court affirmed and upheld the lower court's ruling on the basis that the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
does not add to the privileges or immunities
Privileges or Immunities Clause
The Privileges or Immunities Clause is Amendment XIV, Section 1, Clause 2 of the United States Constitution. It states:Along with the rest of the Fourteenth Amendment, this clause became part of the Constitution on July 9, 1868....
of a citizen and that, historically, "citizen" and "eligible voter" have not been synonymous. Since the United States Constitution
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
did not provide suffrage for women, the Fourteenth Amendment did not confer that right. The court's decision had nothing to do with whether women were considered persons under the Fourteenth Amendment; the court ruled that they were clearly persons and citizens. It rested solely on the lack of provisions within the Constitution for women's suffrage.
Subsequent history
Minor has not been explicitly overruled by another Supreme Court decision. In fact, Minor is still cited for the proposition that the ConstitutionConstitution
A constitution is a set of fundamental principles or established precedents according to which a state or other organization is governed. These rules together make up, i.e. constitute, what the entity is...
does not confer the right to vote. However, as the decision relates to women's suffrage in particular, it is no longer applicable because of the Nineteenth Amendment
Nineteenth Amendment to the United States Constitution
The Nineteenth Amendment to the United States Constitution prohibits any United States citizen to be denied the right to vote based on sex. It was ratified on August 18, 1920....
.
See also
- Nineteenth AmendmentNineteenth Amendment to the United States ConstitutionThe Nineteenth Amendment to the United States Constitution prohibits any United States citizen to be denied the right to vote based on sex. It was ratified on August 18, 1920....
– Provided female citizens of the United States the right to vote. - Women's SuffrageWomen's suffrageWomen's suffrage or woman suffrage is the right of women to vote and to run for office. The expression is also used for the economic and political reform movement aimed at extending these rights to women and without any restrictions or qualifications such as property ownership, payment of tax, or...
- List of United States Supreme Court cases, volume 88