Facts: New York voting law requiring an ability to read and write English as prerequisite to voting conflicts with Voting Right Act of 1965. Voting rights act prohibits denial of voting rights to Puerto Ricans who have completed 6th grade education in English or Spanish.
Issue: whether an Article III court must first rule on the constitutionality of a state law before Congress can pass a law that prohibits the state from regulating voting requirements.
Holding: No. Court concluded that – 5 of the 14th Amend authorized – 4(e) of the Voting Rights Act, which invalidated NY State’s literacy test as applied to persons who had completed the 6th grade in Puerto Rico.
Congress may pass appropriate legislation to enforce the provisions of the 14th amendment and such legislation may override state statutes whether or not the state statutes have been held as unconstitutional by an Article III court. Rationality test: all it must do is be able to perceive a basis upon which the Congress might resolve the conflict as it did, and there can be no doubt that – 4(e) may be regarded as an enactment to enforce the Equal Protection Clause.
If congress only had the right to abolish state laws that are unconstitutional, congress would lose the power granted by Appropriate Legislation clause (Enabling Clause) of the 14th Amendment. This clause gives congress the same broad power that the Necessary and Proper Clause of Article I – 8 clause 18 gives i.e. to enact all necessary and proper legislation to help enforce the Amendments. It is well within Congress’ power to override any state legislation that interferes with the overall purpose of the amendments.
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