JOHN B. HENDERSON, }

_Demurrer. In the Circuit Court of St. Louis County:_ Virginia L.
Minor and Francis Minor, her husband, Plaintiffs, _vs._ Reese
Happersett.

The defendant, Reese Happersett, demurs to the petition of
plaintiffs, and for cause of demurrer defendant states that said
petition does not state facts sufficient to constitute a cause of
action, for the following reasons:

1. Because said Virginia L. Minor, plaintiff, had no right
to vote at the general election held in November, 1872, in
said petition referred to.

2. Because said Virginia L. Minor had no right to be
registered for voting by said defendant, at the time and in
the manner in said petition alleged.

3. Because it was the duty of the defendant to refuse to
place said Virginia L. Minor's name upon the list of
registered voters in said petition referred to.

All of which appears by said petition.

SMITH P. GALT, _Atty for Deft._

The defense, in substance, being based upon the Constitution of
Missouri, which provides (Art. II., Sec. 18) that "every male
citizen of the United States, etc., ... shall be entitled to
vote"; and also upon the registration law of said State, approved
March 10, 1871, which is as follows:

An act to provide for a uniform registration of voters, the
appointment of judges of elections, and repealing all former
acts relating thereto.

_Be it enacted by the General Assembly of the State of
Missouri, as follows:_

SECTION 1.--Every male citizen of the United States, and
every person of foreign birth who may have declared his
intention to become a citizen of the United States,
according to law, not less than one year nor more than five
years before he offers to vote, who is over the age of
twenty-one years, who has resided in this State one year
next preceding his registration as a voter, and during the
last sixty days of that period shall have resided in the
county, city, or town where he seeks registration as a
voter, who is not convicted of bribery, perjury, or other
infamous crime, nor directly or indirectly interested in any
bet or wager depen