South Carolina v. Katzenbach

Impact

As with most landmark civil rights opinions, the Supreme Court’s ruling in South Carolina v. Katzenbach is an important document. As a statement of intent by the Supreme Court that race-based disenfranchisement was not constitutionally permissible, the opinion made clear the Court’s willingness to act (or, alternatively, to accept action on the part of the other branches of the federal government) in defense of African American voting rights. One cannot overstate the importance that this willingness of the Court to act had in the ongoing civil rights process in America. Although the Voting Rights Act shifted much of the enforcement from the courts to the executive branch of the federal government, the Justice Department (not to mention oppressed minority groups) was still going to need the willing assistance of the federal courts. Had the courts proved unwilling to help in these matters, the Justice Department’s lawyers would have faced a much more difficult task in implementing what the voting-rights scholars Chandler Davidson and Bernard Grofman called the “Quiet Revolution” in their landmark book on this process.

Of course, South Carolina v. Katzenbach cannot be viewed in isolation. It was the first ruling by the Supreme Court on the constitutionality of the Voting Rights Act of 1965, but it was not the last. In the next few years, the Court would often return to elements of the act, upholding its provisions time and again. In some instances, such as Allen v. State Board of Elections (1969), which addressed race-based vote dilution as well as vote denial, the Court would significantly expand the reach of the Voting Rights Act. None of this would have happened if the Court had not first upheld the act’s basic constitutionality in Katzenbach.