Neal v. Delaware, 103 U.S. 370 (1881), was a United States Supreme Court case in which the court held that the Fifteenth Amendment invalidated provisions of state constitutions limiting suffrage to whites, and other privileges restricted to voters cannot be restricted based on race.[1][2]

Neal v. Delaware
Argued Mar. 21-22, 1881
Decided May 2, 1881
Full case nameNeal v. Delaware
Citations103 U.S. 370 (more)
Holding
The Fifteenth Amendment invalidated provisions of state constitutions limiting suffrage to whites, and other privileges restricted to voters cannot be restricted based on race.
Court membership
Chief Justice
Morrison Waite
Associate Justices
Nathan Clifford · Samuel F. Miller
Stephen J. Field · Joseph P. Bradley
Ward Hunt · John M. Harlan
William B. Woods
Case opinions
MajorityHarlan, joined by unanimous
ConcurrenceWaite
ConcurrenceField
Laws applied
U.S. Const. amend. XV

Description

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The Delaware Constitution restricted voting to "free white male citizens, of the age of twenty-two years and upwards." Delaware law restricted jury participation to its voting population. Accordingly, Delaware considered only white people for its trial of Neal, a Black man accused of rape. That jury convicted Neal.[1]

The Supreme Court vacated Neal's conviction and invalidated that portion of the Delaware Constitution, saying it was "beyond question" that the Fifteenth Amendment required that result.[1]

References

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  1. ^ a b c Neal v. Delaware, 103 U.S. 370 (1881).
  2. ^ Lieberman, Jethro K. (1999). "Voting, Right to". A Practical Companion to the Constitution. p. 543.
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