Supreme Court under Chief Justice Fuller (Courtesy of the Smithsonian)
In From Jim Crow to Civil Rights (Oxford, 2004), Klarman uses Williams v. Mississippi (1898) to show how the Supreme Court allowed the southern states to disfranchise blacks. He identifies this case as an opposition to racial discrimination in a time when precedent demonstrated that the Supreme Court did little to defend blacks’ political rights.
Williams v. Mississippi involved a black man named Henry Williams who felt he had been cheated out of a fair trial for murder since none of the jury members were black. Williams disputed jury eligibility in Mississippi of literacy tests and poll taxes, “arguing that they had been adopted for a discriminatory purpose and that they conferred unbridled discretion on registrars” (Klarman, 34). The court decided that there was no prejudice against Williams or other blacks in Mississippi’s qualifications for jury members, and that the case lacked any evidence to prove so.
Klarman identifies the rejection of legislative motive as the most important aspect of Williams v. Mississippi. He points to precedent as the reasoning behind the Supreme Court decision as well as “standard of proof,” a level that no black would conceivably achieve during the Plessy-era (Klarman, 36). Ultimately, Klarman sees no real significance to the decision of Williams v. Mississippi because a number of states had already disfranchised blacks, and regardless of the court’s opinion, they would have continued (Klarman, 52-53).
Melville Fuller, acted as the Chief Justice in this case, as well as in the pivotal case of blacks’ rights in Plessy v. Ferguson (1896), and Joseph McKenna wrote the majority opinion. An extensive biography of Fuller, The Chief Justiceship of Melville W. Fuller, 1888-1910 (South Carolina, 1995), by James W. Ely, mentions the feelings of the justices on the case as well as information about Justice Joseph McKenna. In his profile of the case, Ely implies that the justices did not give Williams’ challenge any chance, signifying the view of the court at this time.
For basic background information on disfranchisement, Race and the Jury: Racial Disenfranchisement and the Search for Justice (Plenum Press, 1993) by Hiroshi Fukurai is available in the Dickinson library. There is no significant or recent material on this case in the library, or of Fuller, McKenna, or Williams.
Possibly the best source on this case is the very recent book, Defying Disfranchisement: Black Voting Rights Activism in the Jim Crow South, 1890-1908 (Louisiana State, 2010) by R. Volney Riser, a professor at the University of West Alabama. Riser describes Williams v. Mississippi as a “widely cited, little-studied, and much misunderstood case…the capstone decision of the antidisenfranchisment cases’ first stage” (Riser, 55). He digs deep into the case’s context, pointing to other related cases, as well as details of Mississippi laws. Riser offers insight into black objection against discrimination in Williams v. Mississippi that most historians overlook.
As Volney points out, though everyone seems to mention this case, there is not a lot of work done on the details or the significance of the actual case, besides linking it to disfranchisement. Thus, it was difficult to find sources through databases or on Google books. There are many biographies available on Chief Justice Fuller and Justice McKenna, though nothing particularly noteworthy pertaining to Williams v. Mississippi. Neither Fuller nor McKenna’s biographies on American National Biography include any reference to Williams v. Mississippi nor is Henry Williams listed in the database.
Controversies in Minority Voting: The Voting Rights Act in Perspective (Brookings, 1992) by Bernard Grofman and Chandler Davidson is another book, though not very current, that provides some material on the justices of Williams v. Mississippi and how their politics shaped their decision. Grofman and Davidson suggest that Fuller’s Court was even harsher on black political rights than the previous period. “Whatever potential the Waite Court left, the Court under Chief Justice Melville W. Fuller destroyed” (162).
Williams v. Mississippi remains unexplored and underappreciated. Recent works show that historians have begun to pay more attention to the case and how it represents the United States’ government and court views on black political rights as well as the era of black disfranchisement, though many unanswered questions remain.