Richardson v. Ramirez
Annotate this Case
418 U.S. 24 (1974)
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U.S. Supreme Court
Richardson v. Ramirez, 418 U.S. 24 (1974)
Richardson v. Ramirez
Argued January 15, 1974
Decided June 24, 1974
418 U.S. 24
After the three individual respondents, who had been convicted of felonies and had completed their sentences and paroles, were refused registration to vote in three different California counties respectively because of their felony convictions, they brought a class petition, on behalf of themselves and all other ex-felons similarly situated, for a writ of mandate in the California Supreme Court, naming as defendants the Secretary of State and the three county election officials who had denied them registration "individually and as representatives of the class of all other" county election officials in the State, and challenging the constitutionality of respondents' disenfranchisement on the ground, inter alia, that provisions of the California Constitution and the implementing statutes that disenfranchised ex-felons denied them equal protection. The three county officials named as defendants decided not to contest the action, and told the court they would henceforth register to vote ex-felons, including respondents, whose sentences and paroles had expired. Prior to the return date of the writ, the court added to the named defendants (instead of allowing her to intervene) another county election official (petitioner here) who was the defendant in a similar action by an ex-felon pending in the State Court of Appeal. After holding that the three first-named county officials' acquiescence did not render the case moot, the California Supreme Court went on to hold that the constitutional and statutory provisions in question, as applied to ex-felons whose sentences and paroles had expired, violated the Equal Protection Clause of the Fourteenth Amendment, but did not issue the peremptory writ.
1. In view of its unusual procedural history in the Supreme Court of California, the case is not moot. Pp. 418 U. S. 34-40.
(a) The State Supreme Court's action in adding petitioner as a named defendant after the other named county officials decided not to contest the action, and at a time when the Secretary of
State (who did not join in the petition to this Court) was still a party defendant who had answered the complaint, indicates that the court considered the suit to be not only on behalf of the three named plaintiffs, but also on behalf of all ex-felons in California similarly situated, and also that the court regarded petitioner's opponent in the Court of Appeal suit, both as an unnamed member of the class of ex-felons referred to in the complaint and as one of a class actually seeking to register in petitioner's county, as a party to the Supreme Court action. Pp. 418 U. S. 38-40.
(b) Being rendered in a class action in which relief in the nature of declaratory relief was granted, the decision below is not only binding on petitioner, and thus dispositive of her other suit, but also decides the federal constitutional question presented for the unnamed members of the classes represented below by petitioner and respondents, whose continuing controversy in the State Supreme Court still continues in this Court. Brockington v. Rhodes, 396 U. S. 41, distinguished. P. 418 U. S. 40.
2. California, in disenfranchising convicted felons who have completed their sentences and paroles, does not violate the Equal Protection Clause. Pp. 418 U. S. 41-56.
(a) The understanding of the framers of the Fourteenth Amendment, as reflected in the express language of § 2 of the Amendment, which exempts from the sanction of reduced congressional representation resulting from the denial of citizens' right to vote the denial of such right for "participation in rebellion, or other crime," and in the historical and judicial interpretation of the Amendment's applicability to state laws disenfranchising felons, is of controlling significance in distinguishing such laws from those other state limitations on the franchise that this Court has held invalid under the Equal Protection Clause. Pp. 418 U. S. 54-55.
(b) Section 1 of the Fourteenth Amendment, which contains the Equal Protection Clause, in dealing with voting rights as it does, could not have been meant to bar outright a form of disenfranchisement that was expressly exempted from the less drastic sanction of reduced representation that § 2 imposed for other forms of disenfranchisement. P. 418 U. S. 55.
(c) Even if § 2 was made part of the Amendment "largely through the accident of political exigency, rather than for the relation which it bore to the other sections of Amendment,'" as respondents contend, this does not preclude looking to it for guidance in interpreting § 1, since § 2 is as much a part of the Amendment
as any of the other sections, and how it became part of the Amendment is less important than what it says and what it means. P. 418 U. S. 55.
9 Cal.3d 199, 507 P.2d 1345, reversed and remanded.
REHNQUIST, J., delivered the opinion of the Court, in which BURGER, C.J., and STEWART, WHITE, BLACKMUN, and POWELL, JJ., joined. DOUGLAS, J., filed a dissenting statement, post, p. 418 U. S. 86. MARSHALL, J., filed a dissenting opinion, in which BRENNAN, J., joined and in Part I-A of which DOUGLAS, J., joined, post, p. 418 U. S. 56.