''Grovey v. Townsend'', 295 U.S. 45 (1935), was a

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

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 Sout ...

system to be constitutional. The case was the third in a series of Court decisions known as the "

Texas primary cases 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 C ...

". 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 in ...

'' (1927), Lawrence A. Nixon 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'' (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. However, ''Grovey'' would be overturned nine years later in ''

Smith v. Allwright ''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 thei ...

'' (1944), another of the Texas 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