The 52nd Ohio Infantry itself was a regiment from the state’s southeastern counties, organized in the summer of 1862 and assigned to the Army of the Cumberland. By the time Walker was working with the regiment, it had been through the Perryville campaign and had seen significant action. The regiment would go on to participate in Sherman’s Atlanta campaign in 1864.
## The Nineteenth Amendment and Its Relationship to Walker’s Arguments
Walker died on February 21, 1919. The Nineteenth Amendment was ratified on August 18, 1920. The dates matter for understanding both what she accomplished and what she did not live to see.
The Nineteenth Amendment reads: “The right of citizens of the United States to vote shall not be denied or abridged by the United States or by any State on account of sex.” This is the constitutional amendment approach that Walker had spent decades arguing was unnecessary — that the existing Constitution, properly read, already guaranteed women the right to vote.
She was wrong about the strategy, in the sense that the constitutional argument had been rejected by the Supreme Court in 1875 and had not been revived successfully through any subsequent litigation. The amendment was necessary in the practical sense that without it, women’s voting rights lacked the constitutional guarantee that the Supreme Court would enforce.
Whether Walker was wrong in a deeper sense — whether the existing Constitution, before the Nineteenth Amendment, actually did or should have been understood to include women’s voting rights — is a question of constitutional interpretation that legal scholars have continued to engage with. The Minor v. Happersett decision has been criticized, and some scholars argue that the Fourteenth Amendment, properly interpreted, would have been sufficient to guarantee women’s voting rights without the Nineteenth. Walker’s constitutional argument, in this view, was not wrong in the theoretical sense even if it was practically unavailing in the courts.