ABSTRACT
In Hunter v. Underwood, 471 US 222 (1985), the US Supreme Court held that laws barring convicts from voting, if the laws were enacted with clear discriminatory intent, may violate the Equal Protection Clause of the Fourteenth Amendment to the Constitution. Beyond its significance in voting rights law, Hunter illustrates that the Court will sometimes find that what appear to be racially neutral laws instead violate the Constitution's ban on discrimination. In Hunter the Court reviewed the permanent dis- enfranchisement of two Alabama men convicted of writing bad checks. The state considered that to be a crime of "moral turpitude" and therefore subject to loss of voting rights under section 182 of the Alabama Constitution of 1901. A decade earlier, in Richardson v. Ramirez, 418 US 24 (1974), the Court had held that laws barring convicts from voting were constitutional, and the Hunter Court explicitly declined to reconsider Richardson.
