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Lane v. Wilson 1939 I.W. Lane, resident of Redbird, appealed to Certiorari to the 10th circuit court of appeals, argued March 3rd, 1939 . This comes after I.W. Lane was denied the ability to vote in 1934, after becoming a resident of Redbird, Oklahoma in 1908 (Brophy, Alfred L.)

Oklahoma’s constitution implemented the interpretation under Guinn v. United States related to the 15th amendment that prevented citizens who were eligible to vote in 1916 from voting after that year if they did not register, was a disenfranchisement of African American voters. Lane further asserted that the Oklahoma Constitution's grandfather clause that had reached a decision in 1915 was unconstitutional and prevented African Americans from registering to vote in Red Bird and by extension prevented residents from voting for an undisclosed amount of time if they had failed to vote within the 12-day voter registration period. Justice Frankfurter, who delivered the opinion of the court, struck down the ruling. These provisions were amended through the addition of a literacy test which was circumvented by the grandfather clause (Watts and Stone, p. 2). The grandfather clause was stricken down by the court of appeals on the discriminatory practices based on race and conditions of slavery which those who were had benefited from the grandfather clause weren’t subjected to in relation to Guinn v. United States’ decision that granted immunity prior to the court’s ruling. The courts evaluation of Mr. Lanes claims, the court found that because its relative to Oklahoma statues, there wasn’t a ground for Lane to vote and therefore there was no denial of registration of voting, additionally the court argued that claims of discrimination at a state level before invoking federal judiciary claims.

Based on these evaluations mentioned, the court objected to Lane's claims by first assessing the misapplication of Giles v. Harris 189 U.S. 475 which determined that states were already supervising the equitable outcomes for voters of color and therefore, that the equity of the law cannot undertake now, any more than it has previously to enforce political rights, therefore deeming what Lane is asking for to be considered a special performance from the states perspective (Watts and Stone, p. 5). The court found Lane v. Wilson to be different from Giles v. Harris based on the pretense that the court believes it’s not prepared to claim that an action applied by the law cannot be maintained based on the facts stated in a bill that is proposed (Watts and Stone, p. 6).

References

Alfred L. Brophy, “Lane v. Wilson (1939),” The Encyclopedia of Oklahoma History and Culture, https://www.okhistory.org/publications/enc/entry?entry=LA018. Hendricks, A. (2021, May 5). Guinn v. U.S.: State’s rights and the 15th Amendment - Oklahoma Bar Association. Oklahoma Bar Association - Oklahoma Bar Association. https://www.okbar.org/barjournal/may-2021/hendricks-2021/ Larry O'Dell, “Red Bird,” The Encyclopedia of Oklahoma History and Culture, https://www.okhistory.org/publications/enc/entry?entry=RE014.

Frankfurter, F. & Supreme Court Of The United States. (1938) U.S. Reports: Lane v. Wilson, 307 U.S. 268. [Periodical] Retrieved from the Library of Congress, https://www.loc.gov/item/usrep307268/.