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People v Dean (1866)

One of the first civil rights cases to be heard in Michigan concerning a mixed race black man who sought the right to vote. It was on of the earliest in the nation's struggle to establish political right and suffrage for black men. This right would later be secured with the ratification of the 15th Amendment in 1870. (Women are still not allowed political rights at this time.)

William Dean, a resident of Wayne county, and of 1/16 black and white races, attempted to vote in township elections. He was tried in Wayne County Circuit Court for voting illegally. His case was appealed in Michigan Supreme Court where the plaintiff brought "expert" witnesses to the court to testify on evidence of his black racial ethnicity. Some very ridiculous discussions were had regarding evidence of his racial makeup. Justice Campbell acknowledged in his opinion that although the current law contained prejudice, the case at hand was to determine a definition of whiteness.

Michigan Justices Campbell, Christiancy, and Cooley as a majority concluded that a person was white who had less than one-fourth African blood. (Also referred to at the time as a “Quadroon”) Evidence was presented regarding Dean’s race based on factors such as the cartilage in his nose. Such factors were considered scientific and were based on unfounded and biased opinions of the superiority of specific physical attributes of the white race. Ultimately, Dean was disqualified from voting by the Michigan court. On appeal, Dean was allowed retrial by the US Supreme Court, but only because it was determined that he was ‘white’ based on the definition of whiteness as a race not a color and that he was less than one fourth African.





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