Lexis Nexis - Case Brief

Not a Lexis Advance subscriber? Try it out for free.

Law School Case Brief

Hunter v. Underwood - 471 U.S. 222, 105 S. Ct. 1916, 85 L. Ed. 2d 222, 1985 U.S. LEXIS 2740, 53 U.S.L.W. 4468

Rule:

Official action will not be held unconstitutional solely because it results in a racially disproportionate impact. Proof of racially discriminatory intent or purpose is required to show a violation of the Equal Protection Clause. Once racial discrimination is shown to have been a substantial or motivating factor behind enactment of the law, the burden shifts to the law's defenders to demonstrate that the law would have been enacted without this factor.

Facts:

Appellants challenged the judgment from the United States Court of Appeals for the Eleventh Circuit that declared a voter restriction unconstitutional in favor of appellees in an action where appellees sued appellants under 42 U.S.C.S. §§ 1981, 1983 for a declaration to invalidate Ala. Code § 182 as applied. Appellees challenged their inability to vote under Ala. Code § 182. Appellees alleged that the statute was unconstitutional as it violated their rights under 42 U.S.C.S. §§ 1981, 1983. Appellees sought an invalidation of the statute. Appellants were boards of registrars. Ala. Code § 182 restricted voting privileges for individuals with questionable moral turpitude. The Court held that crimes selected for inclusion in Ala. Code § 182 were believed to have been committed more frequently by African Americans. Ala. Code § 182 was enacted with the intent of disenfranchising African Americans. The Court held there was impermissible racial motivation and a racially discriminatory impact was demonstrated.

Issue:

Does a state’s constitutional provision disenfranchising those persons convicted of, among other offenses, "any crime involving moral turpitude" violate the equal protection clause of the Fourteenth Amendment?

Answer:

Yes.

Conclusion:

The Court held there was impermissible racial motivation and a racially discriminatory impact was demonstrated. The Court affirmed the appellate court's holding in favor of appellees and held that Ala. Code § 182 was unconstitutional. The Court affirmed the appellate court's holding against appellants because the statute that restricted appellees' ability to vote had an impermissible racial motivation and a racially discriminatory impact was demonstrated, therefore, the statute was unconstitutional.

Access the full text case Not a Lexis Advance subscriber? Try it out for free.
Be Sure You're Prepared for Class