In Dixon v. Mississippi (1896) the Mississippi Supreme Court upheld the provisions in the 1890 Mississippi Constitution regarding the qualification of electors, voter registration, and literacy tests. In so doing, the court laid the foundation for the US Supreme Court’s decision in Williams v. Mississippi (1898), affirming the constitutionality of the state’s poll tax, disenfranchisement clauses, literacy test, and grandfather clause.
The case originated when John Henry Dixon, an African American, was indicted, convicted, and sentenced to life in prison for the murder of Nancy Minor. Dixon filed a motion to quash the indictment, asserting that the process of selecting the grand jury discriminated against him. He argued that the state jury commissioners chose potential jurors from a list from which election officers had improperly removed the names of African Americans eligible to serve as jurors. When his motion to quash was overruled, Dixon made a motion to transfer the case from state to federal court because he feared that he could not receive a fair and impartial trial in Mississippi. The trial court denied this motion as well.
Dixon appealed the denial of these motions to the Mississippi Supreme Court. He argued that the provisions providing for voter qualification, voter registration, and the literacy test resulted in discrimination in violation of the Fourteenth Amendment. He asserted that the state election officers discriminated against African Americans when compiling lists of voters to provide to the jury commissioners. The jury commissioners would then choose juries from lists that wrongfully excluded African Americans, thereby preventing them from both serving on juries and receiving fair trials.
The court rejected this argument, explaining that the operation of elections and jury selection functioned independently of one another. The court admitted that election officers had the right to turn away voters deemed unqualified even if they were registered to vote. But while election officers made lists of actual voters, the jury commissioners selected juries from a list of registered voters. Election officers had no power to remove a person from the registered voter list even if they refused to allow that person to vote. From this, the court concluded that even if election officers discriminated against African American voters, this practice had neither harmed Dixon nor deprived him of any constitutional right.
Dixon also argued that the trial court erred in denying his motion to remove the case to federal court. If there was reason to believe that a jury had been selected improperly and that a defendant could not receive a fair and impartial trial, the case was to be removed. The Mississippi Supreme Court held, however, that where a law was not facially discriminatory but discriminatory only in its application, removal to federal court was improper. In those cases, the victim had no judicial remedy. In an effort to explain the clearly discriminatory effects of the laws, the court stated that each of the provisions at issue applied to African American and white citizens alike. It admitted that African Americans were disproportionately affected by these provisions and were prevented from voting in a greater proportionate number than white citizens. However, the court stated that these disproportionate effects arose not because of race but because “of superior advantages and circumstances possessed by the one race over the other,” resulting in “a greater number of the more fortunate race possess[ing] the qualifications which the framers of the constitution deemed essential for the exercise of the elective franchise.”
The Mississippi Supreme Court found that the challenged constitutional provisions did not violate the Fourteenth Amendment. It held that the jury was not improperly selected, the provisions were not facially discriminatory, and Dixon was not denied his right to a fair and impartial trial. Therefore, it held that the trial court properly denied Dixon’s motions to quash the indictment and remove the case to federal court.
Dixon v. Mississippi and its predecessor, Gibson v. Mississippi (1896), are part of a line of cases that provided for a narrow interpretation of the Reconstruction amendments and ushered in an era of widespread discrimination against African Americans.
- Dixon v. Mississippi, 20 So. 839 (1896)
- Gibson v. Mississippi, 162 US 565 (1896)
- Williams v. Mississippi, 170 US 213 (1898)