3/68 15th: Race and the vote

Fifteenth Amendment: No race discrimination in voting

Lesson 3 of 68 · Voting and elections · 6 min read

On this page (7 sections)
  1. The text
  2. History
  3. Section 2 and the Voting Rights Act
  4. In Williams
  5. Common misconceptions
  6. Check yourself
  7. Sources cited on this page

The Fifteenth Amendment says the vote can't be denied because of race. For almost a century states got around it with literacy tests, poll taxes, white primaries and gerrymanders. Courts and Congress gradually shut those down.

Key takeaways

  • Passed by Congress February 26, 1869; ratified February 3, 1870 Verified1.
  • Applies to the United States "or by any State," so it covers every city election directly.
  • Party primaries run under state law count as state action (Smith v. Allwright).
  • Drawing city boundaries to exclude Black voters violates it (Gomillion v. Lightfoot).
  • Section 2 supports the Voting Rights Act.

The text

Official textAmendment XV, Section 1read in context: Amendment XV, Section 1

The right of citizens of the United States to vote shall not be denied or abridged by the United States or by any State on account of race, color, or previous condition of servitude--

Source: National Archives transcription Verified1

Official textAmendment XV, Section 2read in context: Amendment XV, Section 2

The Congress shall have power to enforce this article by appropriate legislation.

Source: National Archives transcription Verified1

History

Grandfather clauses. "One of the first devices declared unconstitutional by the Court was the 'grandfather clause'" Verified2. They let people register without a literacy test if their ancestors had voted before the amendment, which excluded Black voters Verified2.

White primaries. Texas let the Democratic Party exclude Black voters from its primary. The Court held that discrimination "practiced by a party entrusted by Texas law with the determination of the qualifications of participants in the primary" is "state action within the meaning of the Fifteenth Amendment" (Smith v. Allwright, 321 U.S. 649 (1944)) Verified3.

City boundaries. Alabama redrew Tuskegee into an "uncouth twenty-eight-sided figure." The "inevitable effect of this redefinition of Tuskegee's boundaries is to remove from the city all save four or five of its 400 Negro voters while not removing a single white voter or resident" (Gomillion v. Lightfoot, 364 U.S. 339 (1960)) Verified4. The Court held that it stated a Fifteenth Amendment claim.

Section 2 and the Voting Rights Act

South Carolina v. Katzenbach (1966) upheld the Voting Rights Act of 1965 as "an appropriate means for carrying out Congress' constitutional responsibilities" (South Carolina v. Katzenbach, 383 U.S. 301 (1966)) Verified5. Shelby County v. Holder (2013) held that the Act's coverage formula, which was based on voting data from the 1960s and early 1970s, "can no longer be used as a basis for subjecting jurisdictions to preclearance" (Shelby County v. Holder, 570 U.S. 529 (2013)) Verified6. Other parts of the Act, including the nationwide ban on discriminatory practices, remain.

Race-based voter eligibility. Hawaii limited voting for a state agency's trustees to people of Hawaiian ancestry. "Hawaii's denial of Rice's right to vote in OHA trustee elections violates the Fifteenth Amendment" (Rice v. Cayetano, 528 U.S. 495 (2000)) Verified7.

In Williams

  • Annexation and boundaries. Changing city limits to add or drop voters by race is exactly what Gomillion forbids Verified4.
  • Council elections. Whether the council is elected at large or by district, the system can't be designed or maintained to dilute votes by race. California has its own statutory voting-rights law; this site hasn't verified its sections, so check the Elections Code before relying on details.

Common misconceptions

  • "It guarantees everyone the right to vote." It bans only race-based denial. Other amendments cover sex (19th), poll taxes (24th) and age (26th).
  • "Shelby County struck down the Voting Rights Act." It disabled the coverage formula for preclearance; the rest stands Verified6.

Check yourself

Pick an answer for each question. You will see right away if it is right, and why.

Question 1. Why were Texas's white primaries unconstitutional when a private party ran them?

Show the answer and why

The party acted under Texas law, so its exclusion was state action Verified3.

Question 2. What did Alabama do in Gomillion v. Lightfoot?

Show the answer and why

Redrew Tuskegee's boundaries into a 28-sided shape that removed nearly all Black voters from the city Verified4.

Question 3. What part of the Voting Rights Act did Shelby County stop?

Show the answer and why

Use of the Section 4 coverage formula to subject jurisdictions to preclearance Verified6.

Question 4. Scenario: Suppose a plan would redraw the city limits so that mostly voters of one race end up outside. What is the rule?

Show the answer and why

Answer: It's forbidden; that is exactly what Gomillion struck down.

Drawing city boundaries to exclude Black voters violates the Fifteenth Amendment (Gomillion). Changing city limits to add or drop voters by race is exactly what Gomillion forbids.

From this lesson: “Changing city limits to add or drop voters by race is exactly what Gomillion forbids.”

Sources cited on this page

  1. The Constitution: Amendments 11-27 (U.S. National Archives; official; accessed 2026-10-17) ↗
  2. Constitution Annotated: Amendment 15 (Congressional Research Service, Library of Congress (LII copy); unofficial / third-party; accessed 2026-10-23) The Library of Congress's official annotated Constitution (CONAN), read on the Cornell LII copy because constitution.congress.gov blocks our tools. History and background on this site were checked against these essays. ↗
  3. Smith v. Allwright, 321 U.S. 649 (1944) (Legal Information Institute, Cornell Law School (copy of U.S. Supreme Court opinion); unofficial / third-party; accessed 2026-10-23) Full opinion text read on the LII copy. Quotes on this site were machine-checked against that text. ↗
  4. Gomillion v. Lightfoot, 364 U.S. 339 (1960) (Legal Information Institute, Cornell Law School (copy of U.S. Supreme Court opinion); unofficial / third-party; accessed 2026-10-23) Full opinion text read on the LII copy. Quotes on this site were machine-checked against that text. ↗
  5. South Carolina v. Katzenbach, 383 U.S. 301 (1966) (Legal Information Institute, Cornell Law School (copy of U.S. Supreme Court opinion); unofficial / third-party; accessed 2026-10-23) Full opinion text read on the LII copy. Quotes on this site were machine-checked against that text. ↗
  6. Shelby County v. Holder, 570 U.S. 529 (2013) (Legal Information Institute, Cornell Law School (copy of U.S. Supreme Court opinion); unofficial / third-party; accessed 2026-10-23) Full opinion text read on the LII copy. Quotes on this site were machine-checked against that text. ↗
  7. Rice v. Cayetano, 528 U.S. 495 (2000) (Legal Information Institute, Cornell Law School (copy of U.S. Supreme Court opinion); unofficial / third-party; accessed 2026-10-23) Full opinion text read on the LII copy. Quotes on this site were machine-checked against that text. ↗

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