Legal challenges.
The U.S. Supreme Court unanimously upheld the amendment's validity in Leser v Garnett. Maryland citizens Mary D. Randolph, "'a colored female citizen' of 331 West Biddle Street", and Cecilia Street Waters, "a white woman, of 824 North Eutaw Street", applied for and were granted registration as qualified Baltimore voters on October 12, 1920. To have their names removed from the list of qualified voters, Oscar Leser and others brought suit against the two women on the sole grounds that they were women, arguing that they were not eligible to vote because the Constitution of Maryland limited suffrage to men and the Maryland legislature had refused to vote to ratify the Nineteenth Amendment. Two months before, on August 26, 1920, the federal government had proclaimed the amendment incorporated into the Constitution.
Leser said the amendment "destroyed State autonomy" because it increased Maryland's electorate without the state's consent. The Supreme Court answered that the Nineteenth Amendment had similar wording to the Fifteenth Amendment, which had expanded state electorates without regard to race for more than fifty years by that time despite rejection by six states (including Maryland). Leser further argued that the state constitutions in some ratifying states did not allow their legislatures to ratify. The Court replied that state ratification was a federal function granted under Article V of the U.S. Constitution and not subject to a state constitution's limitations. Finally, those bringing suit asserted the Nineteenth Amendment was not adopted because Tennessee and West Virginia violated their own rules of procedure. The Court ruled that the point was moot because Connecticut and Vermont had subsequently ratified the amendment, providing a sufficient number of state ratifications to adopt the Nineteenth Amendment even without Tennessee and West Virginia. The Court also ruled that Tennessee's and West Virginia's certifications of their state ratifications was binding and had been duly authenticated by their respective Secretaries of State. As a result of the Court's ruling, Randolph and Waters were permitted to become registered voters in Baltimore.
Another challenge to the Nineteenth Amendment's adoption was dismissed by the Supreme Court in Fairchild v Hughes, because the party bringing the suit, Charles S. Fairchild, came from a state that already allowed women to vote and so Fairchild lacked standing.
