Alabama followed in 1901, combining the South Carolina and the Louisiana plans and including the usual residence and poll tax requirements, as well as the permanent roll. This was to be made up before December 20, 1902, and included soldiers of the United States, or of the State of Alabama in any war, soldiers of the Confederate States, their lawful descendants, and "men of good character who understood the duties and obligations of citizenship under a republican form of government." After the permanent roll has been made up, the applicant for registration must be able to read and write and must have worked the greater part of the twelve months next preceding, or he or his wife must own forty acres of land or real estate or personal property assessed at not less than three hundred dollars. A long list of disqualifying crimes was added, including wife-beating and conviction for vagrancy. As if this were not enough, after 1903 an applicant for registration might be required to state where he had lived during the preceding five years, the name or names by which known, and the names of his employers. Refusal to answer was made a bar to registration, and wilful misstatement was regarded as perjury. Oklahoma adopted its disfranchising amendment in 1910, without valid reason so far as any one outside the State could see, as the proportion of negroes was very small. An attempt was made permanently to disfranchise the illiterate negro by the "grandfather clause," while allowing illiterate white voters to vote forever. Other States allowed a limited time in which to register on a permanent roll, after which all illiterates were to be disfranchised. Oklahoma sought to keep suffrage permanently open to illiterate whites, while closing it to illiterate negroes. This amendment was declared unconstitutional by the United States Supreme Court in June, 1915, on the ground that a State cannot reëstablish conditions existing before the ratification of the Fifteenth Amendment, even though the disfranchising amendment contained no "express words of exclusion" but "inherently brings that result into existence." ¹ What the Court will do with other similar constitutional amendments when they are brought before it is not so certain. All differ somewhat, and it is possible that the Court may let the whole or a part of some of them stand. If not, it is probable that straight educational and property qualifications will be substituted. In fact, if the Court disapproves the permanent roll but allows the remainder to stand, educational and property qualifications will prevail in several States. ¹ Guinn vs. United States, 238 U. S., 347.