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On September 9, I96I, the United States Commission on Civil Rights submitted to Congress and to the President its I96I Report on Voting. The report contains a detailed exposition of information gathered by the Commission in its investigations and study during the preceding two years, culminating in conclusional findings that "there are reasonable grounds to believe that substantial numbers of Negro citizens are, or recently have been, denied the right to vote on grounds of race or color in about ioo counties in 8 Southern States"; that "a common technique of discriminating against would-be voters on racial grounds involves the discriminatory application of legal qualifications for voters," including "requirements that the voter be able to read and write, that he be able to give a satisfactory interpretation of the Constitution, [and] that he be able to calculate his age to the day"; and that in addition there are denials of "the right to vote . . . in some places ... by the arbitrary or discriminatory application of various registration procedures, such as . . . the rejection of applicants for registration, or the removal of voters from the rolls, on grounds of minor technical errors in the completion of required forms; . . . applying any or all of [specified registration requirements] . . . to some would-be voters but not to others, or applying them differently to different persons; . . . providing assistance to some would-be voters but declining to provide it for others."1 Based in part on these findings, and on the Commission's attendant recommendations,2 several bills embodying corrective measures were introduced in the United States Senate and referred for study to that body's Subcommittee on Constitutional Rights of the Committee on the Judiciary. The principal bill was S. 2750,3 sponsored

Congress and Literacy Tests: A Comment on Constitutional Power and Legislative Abnegation