''Grovey v. Townsend'', 295 U.S. 45 (1935), was a
United States Supreme Court decision that held a reformulation of Texas's
white primaries
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 Ca ...
system to be constitutional. The case was the third in a series of Court decisions known as the "
Texas primary cases".
[
In '']Nixon v. Herndon
''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 ...
'' (1927), Lawrence A. Nixon
Lawrence Aaron Nixon (February 9, 1883 – March 6, 1966) 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 Su ...
sued for damages under federal civil rights laws after being denied a ballot in a Democratic party primary election
Primary elections, or direct primary are a voting process by which voters can indicate their preference for their party's candidate, or a candidate in general, in an upcoming general election, local election, or by-election. Depending on the ...
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. 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
''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 ...
'' (1932), the Court again found in his favor on the basis of the Fourteenth Amendment.
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.[.]
References
External links
*{{caselaw source
, case=''Grovey v. Townsend'', {{ussc, 295, 45, 1935, el=no
, courtlistener =https://www.courtlistener.com/opinion/102431/grovey-v-townsend/
, findlaw=https://caselaw.findlaw.com/us-supreme-court/295/45.html
, justia=https://supreme.justia.com/cases/federal/us/295/45/
, loc =http://cdn.loc.gov/service/ll/usrep/usrep295/usrep295045/usrep295045.pdf
1935 in United States case law
African-American history of Texas
Civil rights movement case law
History of voting rights in the United States
Legal history of Texas
United States Fifteenth Amendment case law
United States Supreme Court cases
United States Supreme Court cases of the Hughes Court
Democratic Party (United States) litigation
Texas elections
Texas Democratic Party
Harris County, Texas
African-American history between emancipation and the civil rights movement
Minority rights case law