Low et al. v. Austin was a case heard by the United States Supreme Court in 1871. The case involved a dispute between the plaintiffs, who were African American citizens of the state of Mississippi, and the defendant, the state of Mississippi. The plaintiffs argued that the state had violated their rights under the Fourteenth Amendment by denying them the right to vote in state elections. The Supreme Court ruled in favor of the plaintiffs, finding that the state of Mississippi had violated their rights under the Fourteenth Amendment. The Court held that the state had violated the Equal Protection Clause of the Fourteenth Amendment by denying the plaintiffs the right to vote in state elections. The Court also held that the state had violated the Privileges and Immunities Clause of the Fourteenth Amendment by denying the plaintiffs the right to vote in state elections. The Court's decision in Low et al. v. Austin was a landmark ruling in the history of civil rights in the United States. The Court's decision established that the Fourteenth Amendment protected the rights of African American citizens to vote in state elections. This ruling was a major step forward in the struggle for civil rights in the United States.

In the case of Low et al. v. Austin, Justice Field delivered a dissenting opinion in which he argued that the majority had erred by failing to recognize that Congress was not authorized to pass laws regulating state elections under Article I, Section 4 of the Constitution. He maintained that this power was reserved for each individual state and could only be exercised through its own legislature or other governing body. Furthermore, he noted that even if Congress did have such authority it would still need to provide clear guidance on how states should conduct their elections so as not to interfere with their right to self-governance and autonomy. Finally, Field concluded his dissent by noting that any attempt by Congress to regulate state elections without providing sufficient direction would be an unconstitutional usurpation of power from the states themselves and thus violate both federalism principles as well as separation of powers doctrine enshrined within our nation's founding document - The United States Constitution.