Garza v. Smith

320 F. Supp. 131
CourtDistrict Court, W.D. Texas
DecidedOctober 23, 1970
DocketCiv. A. SA-70-CA-169
StatusPublished
Cited by17 cases

This text of 320 F. Supp. 131 (Garza v. Smith) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Garza v. Smith, 320 F. Supp. 131 (W.D. Tex. 1970).

Opinions

ROBERTS, District Judge.

Three illiterate Mexican-American voters of Texas, as representatives of all illiterate voters of Texas, have brought this class action to challenge the constitutional validity of Articles 5.05(15) and 8.13 of the Texas Election Code, V.A.T.S. All are qualified voters in Texas, but [132]*132in their affidavits state that because of their illiteracy they find it impossible to vote for all of the candidates of their choice without assistance at the polls. Both of the challenged articles prohibit assistance in marking or preparing ballots to all voters except those who cannot prepare their ballots “* * * because of some bodily infirmity, such as renders [them] physically unable to write or to see”; Article 5.05(15) specifically provides, in respect to absentee ballots, that “* * * no voter shall be entitled to any assistance in the marking of his ballot on the ground of illiteracy.”1 Plaintiffs contend that these provisions offend the [133]*133Fourteenth Amendment by invidiously discriminating between illiterate voters and physically handicapped voters in violation of the Equal Protection Clause and by totally or partially depriving functionally illiterate Texas voters of their fundamental right to vote in violation of the Due Process Clause. For the reasons set out below, we agree with plaintiffs’ claim of discrimination under the Equal Protection Clause and grant declaratory relief.

I. EQUAL PROTECTION

The Supreme Court has long recognized that voting is “ * * * a fundamental political right, because preservative of all rights.” Yick Wo v. Hopkins, 118 U.S. 356, 370, 6 S.Ct. 1064, 1071, 30 L.Ed. 220 (1886); Reynolds v. Sims, 377 U.S. 533, 84 S.Ct. 1362, 12 L.Ed.2d 506 (1964). While the states have long been held to have broad powers to determine the conditions under which the right to vote may be exercised, Lassiter v. Northhampton County Board of Elections, 360 U.S. 45, 79 S.Ct. 985, 3 L.Ed.2d 1072 (1958), once the states grant the franchise, they must not do so in a discriminatory manner. Carrington v. Rash, 380 U.S. 89, 85 S.Ct. 775, 13 L.Ed.2d 675 (1965). Because of the overriding importance of voting rights, classifications that “ * * * might invade or restrain them must be closely scrutinized and carefully confined * * * ” where those rights are asserted under the Equal Protection Clause, especially where lines are drawn on the basis of wealth or race. Harper v. Virginia Board of Elections, 383 U.S. 663, 86 S.Ct. 1079, 16 L.Ed.2d 169 (1966). The test to be applied has been concisely stated, in another context by Mr. Justice Harlan:

The matrix of recent “equal protection” analysis is that the “rule that statutory classifications which either are based on certain ‘suspect’ criteria, or affect ‘fundamental rights’ will be held to deny equal protection unless justified by a ‘compelling’ governmental interest,” * * * Williams v. Illinois, 399 U.S. 235, 90 S.Ct. 2018, 26 L.Ed.2d 586 (June 29, 1970) (concurring opinion).

Thus, in cases questioning the validity of laws conditioning exercise of the right to vote upon the ownership of property or the payment of taxes, the Court has found no such compelling interest attaching to elections concerning public school issues, Kramer v. Union Free School District No. 15, 395 U.S. 621, 89 S.Ct. 1886, 23 L.Ed.2d 583 (1969), revenue bonds, Cipriano v. City of Houma, 395 U.S. 701, 89 S.Ct. 1897, 23 L.Ed.2d 647 (1969), and general obligation bonds, City of Phoenix, Arizona v. Kolodziejski, 399 U.S. 204, 90 S.Ct. 1990, 26 L.Ed.2d 523 (June 23, 1970). The Court has likewise found no compelling state interest to justify a statutory scheme giving established political parties decided advantages over new parties in gaining places on the state ballot to choose presidential electors. Williams v. Rhodes, 393 U.S. 23, 89 S.Ct. 5, 21 L.Ed.2d 24 (1968). Classifications based on race have, of course, been held indefensible even where established by an institution only indirectly connected with state government, such as a political party primary. Terry v. Adams, 345 U.S. 461, 73 S.Ct. 809, 97 L.Ed. 1152 (1953). However, where the statutory scheme under attack is not drawn on the basis of wealth or race and is not shown to have an impact on the citizen’s ability to exercise the fundamental right to vote, a considerably less exacting approach obtains. In such cases, state legislatures are presumed to have acted constitutionally and their statutory classifications will be set aside only if no grounds can be conceived to justify them. “The distinctions drawn by a challenged statute must bear some rational relationship to a legitimate state end and will be set aside as violative of the Equal Protection Clause only if based on reasons totally unrelated to the pursuit of that goal.” McDonald v. Board of Election Commissioners of Chicago, 394 U.S. 802, 809, 89 S.Ct. 1404, 1408, 22 L.Ed.2d 739 (1969), and cases [134]*134cited. Thus the legal standard to be applied in this case depends on the precise basis and effect of the statutes in question.

We begin our consideration of this preliminary problem with an analysis of just what the challenged articles forbid and permit, as evidenced by the statutory scheme of which they are a part. Disregarding certain disqualifications not relevant here and other provisions previously invalidated by court decisions, a qualified Texas voter is defined by the state constitution to be any person “ * * * who shall have attained the age of twenty-one (21) years and who shall be a citizen of the United States and who shall have resided in this State one (1) year next preceding an election and the last six (6) months within the district or county in which such person offers to vote.”2 Thus literacy is not made a prerequisite to voter qualification. The challenged provisions deal /instead with the assistance that may be '"rendered to a voter by election officials in the preparation of his ballot. Moreover, although Article 5.05(15) specifically provides that “no voter shall be entitled to any assistance in the marking of his ballot on the ground of illiteracy,” this must be read together with language in both Article 5.05(15) and Article 8.13 that denies such as{/sistance to all voters except those who are unable to prepare their ballots “because of some bodily infirmity, such as renders [them] physically unable to write or to see.” The statutes therefore prohibit assistance to all voters except those who are unable to perform the mechanical act of voting or visually perceive the ballot.

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Garza v. Smith
320 F. Supp. 131 (W.D. Texas, 1970)

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Bluebook (online)
320 F. Supp. 131, Counsel Stack Legal Research, https://law.counselstack.com/opinion/garza-v-smith-txwd-1970.