Coleman v. Miller (ERA ratification)
Legal Issues
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Overview
Overview
The Supreme Court held that the ratification of a constitutional amendment is a political question not subject to judicial review.
The Facts
Facts
Kansas legislators challenged the ratification of the Nineteenth Amendment (women's suffrage), claiming the state legislature had no authority to ratify. The Kansas Supreme Court upheld the ratification. The U.S. Supreme Court granted certiorari to review whether courts could examine the validity of a state's ratification process.
The Issue
Issue
Whether questions about the procedural validity of a state's ratification of a federal constitutional amendment, including whether a prior rejection bars subsequent ratification, present a justiciable controversy or a nonjusticiable political question.
The Rules
Rule
Coleman v. Miller, 307 U.S. 433 (1939), held that questions about the validity of constitutional amendment ratification procedures are political questions committed to Congress and not appropriate for judicial resolution. Baker v. Carr, 369 U.S. 186 (1962), later refined the political question doctrine, identifying factors including a textually demonstrable constitutional commitment of the issue to a coordinate branch.
The Application
Analysis
When Kansas legislators sought judicial review of the Nineteenth Amendment's ratification, claiming the state legislature lacked authority to ratify, the Court applied the political question doctrine to remove the challenge from judicial consideration. Rather than examining the procedural validity of Kansas's ratification or whether a prior rejection could bar subsequent approval, the Court deferred entirely to Congress's determination that the amendment had been properly ratified by the requisite number of states. The Court reasoned that the Constitution commits the mechanics and finality of amendment ratification to the political branches, specifically Congress, and that judicial review of individual state ratification procedures would create an impermissible conflict with this constitutional design. By holding that courts lack the power to scrutinize how states ratify amendments once Congress has accepted them, the Court insulated Article V procedures from case-by-case judicial second-guessing.
The Conclusion
Conclusion
The Supreme Court held that ratification of constitutional amendments is a political question committed exclusively to Congress, not subject to judicial scrutiny. The Court concluded that once Congress had declared the Nineteenth Amendment ratified, courts could not question the validity of individual state ratifications. This established that Article V amendment procedures are largely beyond judicial review.
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