While I was reading voting rights cases, I though I have to record this funny footnote. Before the civil rights movement, the southern states have literacy requirement for voting. Those requirements typically asked the applicants to prove their ability to read, write, understand and interpret certain matters. The purpose and effect are simple: the illiteracy rate among African American was significantly higher than the whites. By turning down illiterate voters, those states were actually guarding the white dominant voting results.

But even that facially neutral discriminatory rule was enforced in a de facto discriminatory manner. Here is one hilarious example. A white applicant in Louisiana satisfied the registrar of his ability to interpret the state constitution by writing, “FRDUM FOOF SPETGH.” (United States v. State of Louisiana, 225 F.Supp. 353, 384.)

My best guess: “FREEDOM OF SPEECH.”


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