Law School Case Brief
United States v. Classic - 313 U.S. 299
Interference with the right to vote in the Congressional primary in the Second Congressional District for the choice of Democratic candidate for Congress is, as a matter of law and in fact, an interference with the effective choice of the voters at the only stage of the election procedure when their choice is of significance, since it is at the only stage when such interference could have any practical effect on the ultimate result, the choice of the Congressman to represent the district. The primary in Louisiana is an integral part of the procedure for the popular choice of Congressman. The right of qualified voters to vote at the Congressional primary in Louisiana and to have their ballots counted is thus the right to participate in that choice.
Defendant election commissioners were charged with conspiring to willfully alter and falsely count and certify the ballots of votes cast in a state primary election. The district court found that the right to vote in a state primary election was not secured by the United States Constitution. Reversing the judgment, the Court found that U.S. Const. art. 1, § 2 gave qualified voters of each state the right to elect their congressional representatives. The district court sustained a demurrer to two counts of an indictment against or altering election ballots. Plaintiff appealed.
Does the act of the defendant election commissioners come within the meaning of electoral conspiracy to warrant their indictment?
The Court reversed the judgment of the district court because the Constitution gave states the authority to regulate the manner of holding such elections, the right of the elector to have his ballot counted in the state's primary was included in the said Constitutional protection.
Thus, 18 U.S.C.S. § 51, which punished the conspiracy to deprive a citizen of his constitutional rights, covered the conspiracy charged in the indictment. The Court also found that because defendants had acted under color of state law when depriving citizens of their constitutional right to have their vote in the primary counted, 18 U.S.C.S. § 52 was also implicated.
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