During the recent 2022 National Association of Secretaries of State Conference in Baton Rouge, Louisiana the New Mexico Secretary of State’s Office submitted Miguel H. Trujillo for the Margaret Chase Smith American Democracy Award and he was selected to be this year’s recipient. The award will be presented at the NASS 2023 Winter Conference in Washington, D.C.

Miguel H. Trujillo was a tribal educator and former Marine staff Sergeant who, over seventy years ago, made history by initiating a court challenge to a provision in New Mexico’s constitution that barred Native Americans from voting. Trujillo used the American legal system as his weapon in his fight to expand the franchise to all Native Americans in New Mexico, which he accomplished in 1948 after a District Court sided with him and struck down New Mexico’s prohibition on Indian voting as unconstitutional. Trujillo brought his lawsuit to bring equality to all Native Americans and is credited by Pueblo Indians for winning them the right to vote.

As the NASS website explains: “Established in 1992, the Margaret Chase Smith American Democracy Award is named after the former U.S. Senator from Maine, who jeopardized her career by speaking out against the red-baiting tactics of Senator Joseph P. McCarthy in the 1950s. Award recipients are recognized for individual acts of political courage, uncommon character and selfless action in the realm of public service.”

Previous winners of the award can be found here.

To learn more about Miguel H. Trujillo and the lasting impact he has had on voting rights, read our full award submission below:

To the NASS Awards Committee:
When Miguel H. Trujillo walked into the Valencia County Clerk’s office in New Mexico on a sweltering June day in 1948 he probably didn’t know he was making history.
It was on that day that the Marine veteran of World War II, educator, and Isleta Pueblo tribal member was denied his right to register to vote simply because he was Native American. Trujillo’s action that day sparked a series of events that eventually led to all Native Americans in New Mexico gaining the right to vote, twenty-four years after the Indian Citizenship Act granted citizenship to all Native Americans in the United States.
In 1948, Native Americans in New Mexico were denied the right to vote under a provision in the state constitution which barred suffrage for “Indians not taxed,” essentially meaning any Native American living on a reservation or pueblo. This is the provision the Valencia County Clerk used to deny Trujillo when he attempted to register to vote. After Trujillo was refused this right, he brought a lawsuit in the Federal District Court in New Mexico seeking an injunction against the Valencia County election officials.
The courage it took Trujillo to initiate this lawsuit was in keeping with the determination and drive he exhibited throughout his life in service of advancing education and equality for all Native Americans. Even while under constant pressure from family and friends to quit school early in his life in order to support his mother and siblings after his father died, Trujillo understood the transformative power of education and continued his schooling. After graduating from the Albuquerque Indian School, Trujillo went on to the Haskell Institute in Kansas, graduated in 1925, and returned to New Mexico to begin a decades-long career as an educator with the Bureau of Indian Affairs. While working and supporting his family, Trujillo found time to receive his B.A. from the University of New Mexico, even though there were no scholarships available for Indian students at that time.
At the outset of World War II, Miguel Trujillo did what over 25,000 other Native Americans did and enlisted in the armed forces, eventually becoming a Marine staff sergeant. After an honorable discharge at the war’s end, Trujillo returned to teaching in New Mexico at Laguna Pueblo and continued his own education by earning an M.A.
According to his daughter, Miguel Trujillo brought the legal action against Valencia County election officials “in order to bring equality to the Indian people.” Trujillo had been a member of the All Indian Pueblo Council for a number of years but had been frustrated in his attempts to get the Council to coalesce around the issue of suffrage. So, he decided to push ahead on his own.
Trujillo and his attorneys argued in front of a three-judge panel that the provision in New Mexico’s Constitution which excluded “Indians not taxed” from voting was a violation of the Fifteenth Amendment of U.S. Constitution, which says that no one can be denied the right to vote “on account of race, color, or previous condition of servitude.” Trujillo, along with other Native Americans, paid a variety of taxes already, including income taxes, sales taxes, and excise taxes – the only taxes they didn’t pay were ad valorem (i.e. assessed value) taxes on trust status lands.
According to historian Gordon Bronitsky, Trujillo’s attorney’s argued “that denial of the vote to Indians on these grounds violated the equal protection clause because the state of New Mexico permitted untaxed black and white citizens to vote” and that “requiring that Indians pay an ad valorem tax in order to vote was discriminatory, since no other citizen was faced with the tax as a requirement for voting.”
The three-judge panel agreed with Trujillo and on August 3, 1948 handed down a decision that ruled the “Indians not taxed” provision unconstitutional, that all Native Americans had the right to be registered to vote, and that no Native American could be barred from voting because they were an “Indian not taxed.”
The pioneers of expanding democratic rights to all American citizens have come from many backgrounds, have taken many paths to their goals, and are remembered in differing degrees by our histories. Miguel Trujillo has not been as prominently remembered as other civil rights pioneers, but the consequences of his actions have had an enormous impact on expanding the most fundamental of our civil rights. The legacy of Miguel Trujillo is one of dignity, sacrifice, and unwavering dedication to furthering the civil rights of Native Americans.
Later in his life, Trujillo received a Meritorious Award from the Department of the Interior for his “unselfish devotion to Public Service and exceptional interest in the welfare and advancement of Indian People.” He died in 1989 and in his eulogy was remembered as an educator, a devoted family man, and as someone who “fought to make democracy work for all citizens while proudly maintaining his Indian identity and strengths.”
I respectfully submit Miguel H. Trujillo for the 2022 Margaret Chase Smith American Democracy Award.

Maggie Toulouse Oliver
New Mexico Secretary of State