Facts
Prior to the 1960s, many states and municipalities in the United States used literacy tests in order to disenfranchise minorities. In 1959, the U.S. Supreme Court held that literacy tests were not necessarily violations of Equal Protection Clause of the Fourteenth Amendment nor of the Fifteenth Amendment. Lassiter v. Northampton Election Board (1959).
In 1965, Congress passed the Voting Rights Act of 1965, which sought to safeguard the voting rights of previously disenfranchised minorities. Among other provisions, the Voting Rights Act made some literacy tests illegal. Section 4 (e) was aimed at securing the franchisement of New York City's large Puerto Rican population, and "provides that no person who has completed the sixth grade in a public school, or an accredited private school, in Puerto Rico in which the language of instruction was other than English shall be disfranchised for inability to read or write English."
Registered voters in the state of New York brought suit, alleging that Congress exceeded its powers of enforcement under the 14th Amendment and alleging that Congress infringed on rights reserved to states by the 10th Amendment.
Read more about this topic: Katzenbach V. Morgan
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