Williams v. Mississippi (1898)


Landmark Supreme Court case dealing with minority voting rights.

Handed down in the shadow of Plessy v. Ferguson (1896), this decision upheld measures designed to curtail black voting in the South. In 1896 an all-white grand jury in Washington County, Mississippi, indicted Henry Williams, a black man, for murder, and an all-white petit jury subsequently convicted him and imposed a death sentence. Williams argued that both the indictment and trial violated the Equal Protection Clause of the Fourteenth Amendment because the laws of the state of Mississippi disqualified blacks from jury service. Franchise provisions in Mississippi’s 1890 Constitution included a poll tax and literacy test, which had greatly reduced the number of black voters in the state and effectively eliminated blacks from the jury pool. (Williams had failed to pass the literacy test.) The Court rejected Williams’s argument by a vote of 9 to 0 (including Justice John Marshall Har-lan, who had previously cast the only dissenting vote in the Plessy case). In writing the opinion, Justice Joseph McKenna stated that the poll tax and literacy test provisions of the Mississippi Constitution “do not on their face discriminate between the races, and it has not been shown that their actual administration was evil; only that evil was possible under them.” Coupled with the Plessy decision, the outcome of the Williams case was a great victory for the Jim Crow South, and white politicians throughout the region moved quickly to consolidate their position. Armed with legal sanction from the nation’s highest court, other southern states soon adopted similar laws that would keep blacks away from the polls for decades. Minority voting would remain unusually low in the South until after passage of the Civil Rights Act of 1964 and the Voting Rights Act of 1965.

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