Leser v. Garnett (1922): A Landmark Decision on Women’s Suffrage

The Supreme Court case Leser v. Garnett (1922) played a crucial role in affirming the legality of the Nineteenth Amendment, which granted women the right to vote. This ruling was not just a legal formality—it was a pivotal moment that reinforced the constitutional amendment process and ensured the nationwide enforcement of women’s suffrage. The case arose out of lingering resistance to the amendment, and its resolution ended one of the last significant legal challenges to women’s right to vote.

 Background of the Case

For decades, women across the United States fought tirelessly for the right to vote. Leaders like Susan B. Anthony, Elizabeth Cady Stanton, and Alice Paul dedicated their lives to the cause, organizing protests, petitioning lawmakers, and enduring imprisonment to push for suffrage. Their efforts culminated in ratifying the Nineteenth Amendment on August 18, 1920, a historic victory that many believed settled the issue. However, opposition to women’s suffrage did not disappear, and some sought legal avenues to undermine the amendment’s legitimacy.

One such opponent was Oscar Leser, a Maryland resident who opposed women’s suffrage and believed the Nineteenth Amendment had been improperly ratified. Leser filed a lawsuit against the state’s election board after two women, Cecilia Streett Waters and Mary D. Randolph, successfully registered to vote. 

Leser argued that the Nineteenth Amendment was invalid for three reasons. First, some states that ratified it had constitutions explicitly prohibiting women from voting, rendering their ratifications void. Second, he contended that the amendment unlawfully expanded federal authority over state-controlled elections, infringing on states’ rights. Finally, he asserted that certain states, including Tennessee and West Virginia, had ratified the amendment through flawed legislative procedures, making their ratifications illegitimate.

Supreme Court Decision

The case was argued before the U.S. Supreme Court in 1922, with Justice Louis Brandeis—an influential and progressive legal thinker—among the justices presiding over the matter. The Court issued a unanimous (9-0) decision affirming the validity of the Nineteenth Amendment, rejecting all of Leser’s arguments and reinforcing the legitimacy of the amendment.

The Supreme Court’s ruling in Leser v. Garnett reaffirmed the supremacy of federal amendments over state constitutions, declaring that once an amendment is properly ratified, it becomes part of the U.S. Constitution and is binding on all states, regardless of prior state laws. The Court also cited the Fifteenth Amendment, which granted African American men the right to vote, as a precedent to emphasize that states cannot refuse to comply with a duly ratified constitutional amendment.  Brandis wrote, “This amendment is in character and phraseology precisely similar to the Fifteenth. For each the same method of adoption was pursued. One cannot be valid and the other invalid.” The Court also decided that the states in question had followed the proper legislative procedures when they ratified the Nineteenth Amendment, so any challenge to their legitimacy was not relevant.

Justice Brandeis, known for his thoughtful legal philosophy and advocacy for social justice, likely saw this case as another affirmation of democratic progress. His presence on the bench lent weight to the Court’s decision, as he was a strong proponent of broad democratic participation and judicial restraint when faced with political questions.

 Significance and Impact

The decision in Leser v. Garnett had profound implications for American democracy. By upholding the Nineteenth Amendment, the Supreme Court reinforced the strength of the constitutional amendment process and ensured that women’s voting rights were permanently protected. This ruling sent a clear message that the federal government had the authority to enforce voting rights, even if some states resisted.

This decision was more than a legal victory for women—it confirmed their place in democracy. It meant that their hard-fought battle for the ballot was secured not just by activism but also by the highest court in the land. It also discouraged further legal attempts to undermine the amendment and demonstrated that political opposition could not easily overturn constitutional changes.

Leser v. Garnett (1922) was a definitive moment in American legal and political history. It marked the final judicial endorsement of women’s suffrage and underscored the authority of constitutional amendments over state laws. The case serves as a reminder of the struggles faced by those who fought for voting rights and highlights the judiciary’s role in upholding the principles of democracy. Today, the ruling remains an essential part of the broader story of civil rights in the United States, reinforcing the idea that once hard-won rights must be vigilantly protected for future generations.

References 

Urofsky, Melvin I, Louis D. Brandeis: A Life. New York, Pantheon Books, 2009.