Grovey v. Townsend | |
---|---|
Argued March 11, 1935 Decided April 1, 1935 | |
Full case name | R. R. Grovey v. Townsend |
Citations | 295 U.S. 45 ( more ) 55 S. Ct. 622; 79 L. Ed. 1292 |
Holding | |
Democratic Party of Texas private rule banning blacks from voting in primary elections was constitutional. | |
Court membership | |
| |
Case opinion | |
Majority | Roberts, joined by unanimous |
Laws applied | |
U.S. Const. amend. XV | |
Overruled by | |
Smith v. Allwright (1944) |
Grovey v. Townsend, 295 U.S. 45 (1935), was a United States Supreme Court decision that held a reformulation of Texas's white primaries system to be constitutional. The case was the third in a series of Court decisions known as the "Texas primary cases". [1]
In Nixon v. Herndon (1927), [2] Lawrence A. Nixon sued for damages under federal civil rights laws after being denied a ballot in a Democratic party primary election on the basis of race. The Court found in his favor on the basis of the Fourteenth Amendment, which guarantees equal protection under the law, while not discussing his Fifteenth Amendment claim. [3] After Texas amended its statute to authorize the political party's state executive committee to set voting qualifications, Nixon sued again; in Nixon v. Condon (1932), [4] the Court again found in his favor on the basis of the Fourteenth Amendment. [5]
The Democratic Party of Texas state convention then adopted a rule banning black voting in primary elections. R. R. Grovey, a black Texas resident, sued Townsend, a county clerk enforcing the rule, for violation of Grovey's civil rights under the Fourteenth and Fifteenth Amendments. The Court unanimously upheld the party's rule as constitutional, distinguishing the discrimination by a private organization from that of the state in the previous primary cases. [1] [6] However, Grovey would be overturned nine years later in Smith v. Allwright (1944), another of the Texas primary cases. [1] [7]
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments. Usually considered one of the most consequential amendments, it addresses citizenship rights and equal protection under the law and was proposed in response to issues related to formerly enslaved Americans following the American Civil War. The amendment was bitterly contested, particularly by the states of the defeated Confederacy, which were forced to ratify it in order to regain representation in Congress. The amendment, particularly its first section, is one of the most litigated parts of the Constitution, forming the basis for landmark Supreme Court decisions such as Brown v. Board of Education (1954) regarding racial segregation, Loving v. Virginia (1967) regarding interracial marriage, Roe v. Wade (1973) regarding abortion, Bush v. Gore (2000) regarding the 2000 presidential election, Obergefell v. Hodges (2015) regarding same-sex marriage, and Students for Fair Admissions v. Harvard (2023) regarding race-based college admissions. The amendment limits the actions of all state and local officials, and also those acting on behalf of such officials.
The Fifteenth Amendment to the United States Constitution prohibits the federal government and each state from denying or abridging a citizen's right to vote "on account of race, color, or previous condition of servitude." It was ratified on February 3, 1870, as the third and last of the Reconstruction Amendments.
Stanley Forman Reed was an American lawyer and jurist who served as an Associate Justice of the U.S. Supreme Court from 1938 to 1957. He also served as U.S. Solicitor General from 1935 to 1938.
Smith v. Allwright, 321 U.S. 649 (1944), was a landmark decision of the United States Supreme Court with regard to voting rights and, by extension, racial desegregation. It overturned the Texas state law that authorized parties to set their internal rules, including the use of white primaries. The court ruled that it was unconstitutional for the state to delegate its authority over elections to parties in order to allow discrimination to be practiced. This ruling affected all other states where the party used the white primary rule.
United States v. Carolene Products Company, 304 U.S. 144 (1938), was a case of the United States Supreme Court that upheld the federal government's power to prohibit filled milk from being shipped in interstate commerce. In his majority opinion for the Court, Associate Justice Harlan F. Stone wrote that economic regulations were "presumptively constitutional" under a deferential standard of review known as the "rational basis test".
The Reconstruction Amendments, or the Civil War Amendments, are the Thirteenth, Fourteenth, and Fifteenth amendments to the United States Constitution, adopted between 1865 and 1870. The amendments were a part of the implementation of the Reconstruction of the American South which occurred after the Civil War.
White primaries were primary elections held in the Southern United States in which only white voters were permitted to participate. Statewide white primaries were established by the state Democratic Party units or by state legislatures in South Carolina (1896), Florida (1902), Mississippi and Alabama, Texas (1905), Louisiana and Arkansas (1906), and Georgia (1900). Since winning the Democratic primary in the South at the time almost always meant winning the general election, barring black and other minority voters meant they were in essence disenfranchised. Southern states also passed laws and constitutions with provisions to raise barriers to voter registration, completing disenfranchisement from 1890 to 1908 in all states of the former Confederacy.
Nixon v. Herndon, 273 U.S. 536 (1927), was a United States Supreme Court decision which struck down a 1923 Texas law forbidding blacks from voting in the Texas Democratic Party primary. Due to the limited amount of Republican Party activity in Texas at the time following the suppression of black voting through poll taxes, the Democratic Party primary was essentially the only competitive process and chance to choose candidates for the Senate, House of Representatives and state offices.
Nixon v. Condon, 286 U.S. 73 (1932), was a voting rights case decided by the United States Supreme Court, which found the all-white Democratic Party primary in Texas unconstitutional. This was one of four cases brought to challenge the Texas all-white Democratic Party primary. All challenges were supported by the National Association for the Advancement of Colored People (NAACP). With Smith v. Allwright (1944) the Supreme Court decisively prohibited the white primary.
Terry v. Adams, 345 U.S. 461 (1953), was a United States Supreme Court decision that held white-only pre-primary elections to be unconstitutional. It was the last in a series of court cases addressing the system of white primaries designed to disenfranchise African-American voters in the southern United States.
Carter Walker Wesley was an American lawyer, newspaperman and political activist.
The Stone Court refers to the Supreme Court of the United States from 1941 to 1946, when Harlan F. Stone served as Chief Justice of the United States. Stone succeeded the retiring Charles Evans Hughes in 1941, and served as Chief Justice until his death, at which point Fred Vinson was nominated and confirmed as Stone's replacement. He was the fourth chief justice to have previously served as an associate justice and the second to have done so without a break in tenure. Presiding over the country during World War II, the Stone Court delivered several important war-time rulings, such as in Ex parte Quirin, where it upheld the President's power to try Nazi saboteurs captured on American soil by military tribunals. It also supported the federal government's policy of relocating Japanese Americans into internment camps.
This is a timeline of voting rights in the United States, documenting when various groups in the country gained the right to vote or were disenfranchised.
The White Municipal Party was a white supremacist political organization established in Tampa, Florida to eliminate African American influence in municipal elections. The group limited local elections to white candidates for many years by excluding African Americans from party membership and thereby blocking them from participating in primary elections where the eventual election winners were actually determined. The party produced an unbroken series of mayors in Tampa from 1910 until 1947.
African Americans were fully enfranchised in practice throughout the United States by the Voting Rights Act of 1965. Prior to the Civil War and the Reconstruction Amendments to the U.S. Constitution, some Black people in the United States had the right to vote, but this right was often abridged or taken away. After 1870, Black people were theoretically equal before the law, but in the period between the end of Reconstruction era and the passage of the Civil Rights Act of 1964 this was frequently infringed in practice.
The Terrell Election Law was part of a wave of election reform legislation instituting a poll tax, secret ballot, and a closed primary system in Texas from 1902 to 1907, during the Progressive Era of United States history. The 1903 law allowed parties to restrict who could vote in their primaries, paving the way to exclude African-American voters from Democratic Party primaries. A poll tax had been established in 1902 and both laws disenfranchised African Americans. The Terrell Law was named for Alexander W. Terrell. The law was revised in 1905–1906. A 1923 amendment established a complete ban on African Americans voting in any Democratic Party primaries. Lawrence Aaron Nixon sued and the law was eventually thrown out by the U.S. Supreme Court. A modified version of the law was passed by the Texas Legislature and again thrown out upon reaching the U.S. Supreme Court in a suit filed by Nixon. The decision was written by Justice Benjamin N. Cardozo.
Lawrence Aaron Nixon was a medical doctor in El Paso, Texas who twice fought state election laws barring African-Americans from voting in Democratic Party primaries in Texas all the way to the United States Supreme Court. He was never allowed to join the El Paso Medical Society because of his African-American heritage.