Subsequent History
The Nineteenth Amendment to the Constitution, ratified in 1920, prohibited sex-based denial or abridgment of any United States citizen's right to vote—thus effectively overruling the key holding in Minor v. Happersett. In some later voting rights cases, however, Minor was cited in opposition to the claim that the federal Constitution conferred a general right to vote, and in support of restrictive election laws involving poll taxes, literacy tests, and the role of political parties in special elections.
In the 1960s, the Supreme Court started to view voting as a fundamental right covered by the Equal Protection Clause of the Fourteenth Amendment. In a dissenting opinion of a 1964 Supreme Court case involving reapportionment in the Alabama state legislature, Associate Justice John Marshall Harlan II included Minor in a list of past decisions about voting and apportionment which were no longer being followed.
Read more about this topic: Minor V. Happersett
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