People v. Dean (Michigan)

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The issue in the case, People v. Dean (1866), was whether or not a man who was part black was eligible to vote. The Civil War had just ended, and advocates for black male suffrage and equal rights in general were at the peak of their influence. Dean, who was determined to be of approximately “one-sixteenth” African descent, was found to be in violation of a Michigan Constitutional provision granting suffrage only to “white male citizens”. In his written opinion, Campbell interpreted the law to include persons with “less than one-fourth of African-blood”. Under this ruling, Dean was eligible to vote because he was only one-sixteenth African. Explaining his reasoning in this decision, Campbell asserted, “…the right of the people to determine the qualification of electors is undisputed. We are bound to adhere to the rule they have established. The right to vote is granted to a certain designated class, and to no others”. While Justices Cooley and Christiancy both concurred with this ruling, George Martin dissented, calling the exclusion of blacks from the right to vote a “rule of slavery” and questioning the courts authority to exclude persons with any level of African blood from full citizenship.

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