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LANE v. WILSON (1939)

Lane v. Wilson struck down Oklahoma's 1916 voting registration law, which was passed in the aftermath of Guinn v. United States (1915). The registration law, enacted by a legislature that had been chosen in an election from which blacks were illegally excluded, automatically qualified all persons who had voted in 1914. Those who had been previously excluded from voting--or had not voted in 1914--had only twelve days (April 30 to May 11) to register. If they failed to register, they permanently lost the right to vote.

I. W. Lane, a black man born in Alabama and a resident of Red Bird in Wagoner County since 1908, attempted to register in 1934. The county registrar, who said he "was instructed by higherups not to register any colored person," refused to register him. Following that, Lane filed suit in federal court. The trial court and court of appeals both rejected Lane's claim of discrimination, observing that the law barred whites as well as blacks who had neither voted in 1914 nor registered in 1916.

U.S. Supreme Court Justice Felix Frankfurter saw the case differently. He focused on the automatic grant of voting rights to many white citizens and the narrow window for blacks to register. Frankfurter thought there was "no escape from the conclusion that the means chosen as substitutes for the invalidated 'grandfather clause' were themselves invalid under the Fifteenth Amendment," for the 1870 amendment "nullifies sophisticated as well as simple-minded modes of discrimination."

Lane v. Wilson (1939) was an important step towards ensuring equal voting rights. It is also an example of the Supreme Court's "realist" jurisprudence, which looked beyond the language of a statute to its practical effect when judging its constitutionality.

SEE ALSO: AFRICAN AMERICANS, CIVIL RIGHTS, ROSCOE DUNJEE, GUINN v. UNITED STATES, AMOS HALL, JUDICIARY, NAACP, RED BIRD, SEGREGATION

BIBLIOGRAPHY: Randall Kennedy, "Race Relations Law and the Tradition of Celebration: The Case of Professor Schmidt," Columbia Law Review 86 (December 1986). Lane v. Wilson, 98 F.2d 980, 980 (10th Cir. 1938). Lane v. Wilson, 307 U.S. 268, 270 (1939).

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