Guinn V. United States - The Aftermath

The Aftermath

The decision had little short-term effect in Oklahoma. Although the grandfather clause was struck down as unconstitutional, the state legislature immediately passed a new statute restricting voter registration. It provided that "all persons, except those who voted in 1914, who were qualified to vote in 1916 but who failed to register between April 30 and May 11, 1916, with some exceptions for sick and absent persons who were given an additional brief period to register, would be perpetually disenfranchised."

Because of the Supreme Court decision in 1915, similar grandfather clause provisions in the constitutions of Alabama, Georgia, Louisiana, North Carolina, and Virginia were struck down as unconstitutional. In most of those states, legislators also quickly devised other statutory approaches to limit black voter registration and voting.

Twenty-three years later, the Supreme Court struck down the statute which Oklahoma had passed to replace the grandfather clause in Lane v. Wilson, 307 U.S. 268 ( 1939). The Court concluded that "the means chosen as substitutes for the invalidated 'grandfather clause' were themselves invalid under the Fifteenth Amendment. They operated unfairly against the very class on whose behalf the protection of the Constitution was here successfully invoked."