Richardson v. Ramirez
Margaret Huai
To what extent should ex-incarcerated individuals' citizenship rights be limited?
BACKGROUND:
Docket: 72-1589
Citation: 418 U.S. 24 (1974)
Date Argued: January 15th, 1974
Date Decided: June 24th, 1974
Following the release of three convicts from prison, they were barred by Mendocino County election officials under the jurisdiction of County Clerk Viola Richardson from registering to vote in three different California counties due to their status as formerly convicted individuals. According to the plaintiffs, disenfranchising these released inmates would allow the California Secretary of State to permanently disenfranchise people convicted of “infamous crimes.” And so, in 1973, the ex-convicts came together and brought a class action lawsuit to represent damages inflicted on a group of similarly affected plaintiffs against the State of California’s Secretary of State and the three election officials who denied them voter registration. The California Supreme Court ordered lower government officials to correct an indiscretion using a writ of mandamus and agreed that denying the three individuals their suffrage was not an equal protection of their voting rights. However, the US Supreme Court reviewed a lower court’s ruling, reversing the ruling of the California Supreme Court on the grounds that a state can disenfranchise (remove voting rights) of felons without proving the process serves a compelling state interest.
PRESIDING QUESTIONS:
Does denying voter registration for ex-prisoners violate the idea of equality?
OUTCOME - 6-3 IN FAVOR OF RICHARDSON
In the majority opinion, the justices ruled that Section Two of the Fourteenth Amendment reduces representation in the House for states that disenfranchise voters, except in the case of disenfranchising voters who have rebelled or committed crimes. Additionally, limiting voting rights for a compelling state interest did not have to be applied to felon or ex-felon disenfranchisement due to how common felon disenfranchisement was at the time.
The dissenting opinion disagreed with the majority because they argued that Section Two actually stated that felons were not to be counted for Congressional apportionment, which meant that there were fewer Constitutional restrictions for courts to uphold denying voting rights for formerly incarcerated individuals.
PARTIES AND OPINIONS
Side 1- Abran Ramirez et al. (Respondent)
Ramirez, Lee, and Gill were the three ex-felons who were disenfranchised in San Luis Obispo County, Monterey County, and Stanislaus County.
Respondent Argument (Dissenting): Ex-felon disenfranchisement was a violation of the Equal Protection Clause of the Fourteenth Amendment, and there was no issue with the California Supreme Court’s ruling.
Side 2- Viola N. Richardson (Petitioner)
Richardson was the County Clerk of Mendocino County, where the disenfranchisement of the three ex-incarcerated individuals occurred.
Petitioner Argument (Majority): There needed to be intervention with the lower court’s ruling since Richardson believed the three respondents colluded to formulate a case that the county could not reasonably contest.
SIGNIFICANCE
The Fourteenth Amendment was a civil rights amendment intended to uphold African-American freedmen's civil liberties after the Civil War ended. Limiting the right to vote and other foundational civil liberties are generally unconstitutional under this amendment, as established during the Reconstruction period. Richardson v. Ramirez (1974) was a shift in perspective on qualifying voting rights and disenfranchisement, which the Supreme Court would continue developing a judicial interpretation of. Even today, the repercussions of these constantly evolving judicial interpretations of voting rights and protections are essential to determining the framework of American democracy since voting is an essential method for citizens to express their consent to be governed by their representative officials.