Miller strongvstrong. Johnson The Supreme Court Remaps Shaw strongvstrong. Reno.pdf

Louisiana Law R eview Volume 56 | Number 4 Punitive Damages Sy mp osium Summer 1996 Miller v. Johnson: The Supreme Court Remaps Shaw v. Reno J ennifer Denise Rogers Repository Citation J ennifer Denise Ro ers, Miller v. Johnson: e Supr eme Court Remaps Shaw v. Reno, 56 La. L. Rev. (1996) Available at : http://di /lalrev/vol56/iss4/9 This Note is brought to you for free and open access by the Law R eviews and Journals at Di italCommons @ LSU Law Center. It has been accepted for inclusion in Louisiana Law R eview by an authorized administrator of Di italCommons @ LSU Law Center. For more information, please contact sarah.buras@. Miller v. Johnson: The Supreme Court Remaps Shaw v. Reno I. INTRODUCTION The right to vote in free elections and participate in the political process is the most basic right in a democratic society. After the Civil War, the United States Constitution was twice amended in hopes of insuring to former slaves the same rights that white male citizens already enjoyed-equal protection of the laws and the right to vote. Many states however, especially in the Deep South, successfully ignored this constitutional imperative for upwards of a century through race-neutral devices such as poll taxes, grandfather clauses, and literacy tests.2 In the early 1960s, the United States Supreme Court began to employ the Equal Protection Clause of the Fourteenth Amendment of the United States Constitution to protect the civil rights of minorities, including the right to vote. In 1965, Congress made use of its enforcement powers under the Fifteenth