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While in the true sense, U.S. Const. amend. XV gives no right of suffrage, in operation its prohibition might measurably have that effect; that is to say, that as the command of the Fifteenth Amendment is self-executing and reaches without legislative action the conditions of discrimination against which it is aimed, the result might arise that as a consequence of the striking down of a discriminating clause a right of suffrage is enjoyed by reason of the generic character of the provision which remains after the discrimination is stricken out.
The government brought an action against defendant state officers, alleging they conspired to deprive certain citizens of their right to vote in a state election. The state officials were convicted. On appeal, the state officials contended that the states had the power to fix standards for suffrage, and that such power was not taken away by the Fifteenth Amendment. On the other hand, the government argued that the provision of an Oklahoma constitutional amendment that fixed a voting standard based upon a date prior to the adoption of the Fifteenth Amendment was repugnant to the self-executing prohibitions of the Fifteenth Amendment. The Circuit Court of Appeals for the Eighth Circuit certified two questions to the United States Supreme Court for resolution.
The Court answered the first certified question in the negative, holding that the amendment to the Oklahoma constitution was invalid, and the second question in the positive, as the amendment was void in its attempt to deny citizens the right to vote based on pre-Fifteenth Amendment standards. The Court reasoned that the state constitutional amendment created a standard of voting, but was in substance a revitalization of conditions that had been destroyed by the self-operative force of the Fifteenth Amendment.