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The Myers v. Anderson case in 1914 revolved around the issue of voting rights for African Americans in Maryland. The plaintiffs, three black men named John H. Myers, William E. Adams and Charles Johnson, sued Frank M. Anderson and other election officials after they were denied the right to vote due to a grandfather clause implemented by the state of Maryland that effectively disenfranchised many African American voters who could not prove their grandfathers had voted before 1867. The Supreme Court ruled unanimously against this clause stating it was unconstitutional as it violated the Fifteenth Amendment which prohibits racial discrimination in voting rights. This decision marked an important step towards ensuring equal voting rights for all citizens regardless of race or color.
In the dissenting opinion for Myers and Others v. Anderson, Justice Holmes disagreed with the majority's decision to uphold Maryland's law that required citizens to pay a poll tax in order to vote. He argued that this requirement was unconstitutional as it violated the Fifteenth Amendment by indirectly disenfranchising African American voters who were unable or unwilling to pay the tax. Holmes contended that while states have broad powers over their own elections, they cannot violate federal constitutional rights under any circumstances. He further asserted that although there may not be explicit racial discrimination within these laws, if their effect is racially discriminatory then they should be deemed unconstitutional. This interpretation of equal protection under law would later become influential in civil rights cases challenging similar voting restrictions.