The Court reasoned that the rule restricting primary voters to whites denied Smith equal protection under the law in violation of the Fourteenth Amendment. Smith, a black Texas voter, sued the county election official, Allwright, for damages of $5,000 for denying him the right to vote in the Democratic primary. It is suggested that Grovey v. Townsend was overruled sub silentio in United States v. Classic, 313 U.S. 299, 61 S.Ct. 319 U.S. 738. Although the county officials in this case argue that the Democratic party is a voluntary, non-governmental organization, the Court believes they are State actors for purposes of primary elections. Thus, the State permitting the Democratic party to allow only white voters participate in the Democratic primary is State action in violation of the Constitution. 1031, 85 L.Ed. Smith v. Allwright is a landmark case because it ensured that racial discrimination cannot occur in general or primary elections under the Constitution. Following is the case brief for Smith v. Allwright, 321 U.S. 649 (1944). Did denying blacks the right to vote in primary elections violate the Constitution?

[2], It was the watershed in the struggle for Black rights, and it signaled the beginning of the Second Reconstruction and the modern civil rights movement. This phase of the case is not considered further as the decision on the merits determines the legality of the action of the respondents. Thus, because the Democratic party is not a governmental organization, it falls outside the reach of the Constitution. Smith v. Allwright (1944), was a landmark decision by the United States Supreme Court. The majority concluded that several state laws made the Texas primary more than just a function of a private organization. The lower courts were correct to follow the Court’s Grovey v. Townsend decision, which held that political parties are not State actors. Mr. Smith, a black Texas voter, sued election officials in his county for denying him the right to vote in the Democratic primary in 1940. Lonnie E. Smith, a black dentist from the Fifth Ward area of Houston and a voter in Harris County, Texas, sued county election official S. S. Allwright for the right to vote in a primary election being conducted by the Democratic Party. The judgment entered declared the denial was constitutional. By delegating its authority to the Democratic Party to regulate its primaries, the state was allowing discrimination to be practiced, which was unconstitutional. Its organic law grants to all citizens a right to participate in the choice of elected officials without restriction by any state because of race. It is a violation of the Fourteenth and Fifteenth Amendments to deny a person the right to vote in a primary based on race, and a political party running a primary election acts as an agent of the State for constitutional purposes. Justice Frankfurter concurred in the result with no additional opinion. The Supreme Court may overrule a previous decision if it is believed erroneous upon reexamination. The United States is a constitutional democracy. This grant to the people of the opportunity for choice is not to be nullified by a state through casting its electoral process in a form which permits a private organization to practice racial discrimination in the election. 1345, 1356 n.69 (2003) (citing Alexander Keyssar, The Right to Vote: The Contested History of Democracy in the United States 248 (2000)). The Court was wrong to overturn the recent decision in Grovey. The Court’s reputation for stability and consistency is challenged if decisions can so easily be overruled. 5 We granted the petition for certiorari to resolve a claimed inconsistency between the decision in the Grovey case and that of United States v. Classic, 313 U.S. 299. He challenged the 1923 state law that authorized the party to establish its internal rules; the party required all voters in its primary to be white. L. Rev. (adsbygoogle = window.adsbygoogle || []).push({}); Planned Parenthood of Southeastern Pennsylvania v. Casey. Smith v. Allright was a landmark U.S. Supreme Court decision resulting from a court case that originated in Texas. The number of Southern blacks registered to vote rose to between 700,000 and 800,000 by 1948 and then to one million by 1952. In Smith v.Allwright, Thurgood Marshall rose in front of the United States Supreme Court to argue that Texas’s Democratic primary system allowed whites to structurally dominate the politics of …

In an opinion written by Justice Stanley F. Reed, the Court struck down the law. of Education: The collapse of the white Democratic primary, despite fond hopes, has not resulted in full participation by all in the political life of the South. [5] Steven F. Lawson, Black Ballots: Voting Rights in the South 1944-1969, at 46 (1976). In Smith v. Allwright (1944), eight justices on a Supreme Court with several new members overturned the Grovey decision. 1368. The decision made it unconstitutional to keep African Americans from voting in a Democratic Party primary in Texas. The District Court and Court of Appeals denied Smith’s lawsuit, relying on the Supreme Court opinion in Grovey v… Smith, a black Texas voter, sued the county election official, Allwright, for damages of $5,000 for denying him the right to vote in the Democratic primary. In so ruling, Smith overruled a unanimous nine year old decision in Grovey v. Townsend that held that the Texas Democratic Party’s race-based restrictions on voting in primaries was constitutional because it was not state action, and thus it had not been endorsed or authorized by the state. The political and social advances of Blacks simply could not have occurred without the changes that came in the wake of the overthrow of the Democratic white primary. It is desirable to adhere to former Court decisions.

In 1923, the Texas Democratic Party required all voters in its primary to be white based on a state law authorizing the party to establish its own internal rules. [4] Pamela S. Karlan, Ballots and Bullets: The Exceptional History of the Right to Vote, 71 U. Cin. The Fourteenth and Fifteenth Amendments are clear that no citizen should be denied the right to vote because of race.
[3], Marshall characterized the ruling of Smith, which he considered his most important case,[4] as “so clear and free of ambiguity” that the right of Blacks to participate in primaries was established “once and for all.”[5], African-American voter registration vastly improved immediately following the Court’s ruling in Smith, causing Marshall to recognize the case as “a giant milestone in the progress of Negro Americans toward full citizenship.”[6]. [6] Editorial, 116,000 Georgia Registrants, 53 The Crisis 201, 201 (July 1946). For, if nothing else, it indicates the fate which awaits the ‘legal means’ which some of the Southern states have drafted to preserve segregated schools.[7]. He sought $5,000 in damages. Lonnie E. Smith, a black voter in Harris County, Texas, sued county election official S. S. Allwright for the right to vote in the primary. Therefore, expressly overrules that case. Star Athletica, L.L.C. The U.S. Supreme Court granted certiorari. The Democratic Party in the State of Texas only allowed white people to vote in Democratic primaries. [ Footnote 5 ] Smith v. Allwright, 5 Cir., 131 F.2d 593. The county election officials argued that Smith did not have a constitutional right to vote in the Democratic primary because the Democratic primary is run by a volunteer party organization, not the State of Texas. The Democratic Party had controlled politics in the South since the late 19th century and the state legislatures The Fifth Circuit Court of Appeals decision is reversed. Can the Supreme Court overrule a previous decision regarding the application of the Constitution if it believes that the previous decision was erroneous? The District Court denied the relief sought and the Circuit Court of Appeals quite properly affirmed its action on the authority of Grovey v. Townsend, 295 U.S. 45. © Copyright 2020 NAACP Legal Defense and Educational Fund, Inc. But that principle does not preclude the Court from reexamining a prior ruling. Instead, these laws made it … The Texas Democratic Party had a rule in place that only allowed white people to vote in Democratic primaries.

However, upon reexamination, the Court believes that Grovey was wrongly decided. In 1923, the Texas Democratic Party required all voters in its primary to be white based on a state law authorizing the party to establish its own internal rules. v. Varsity Brands, Inc. Lonnie E. Smith, a black voter in Harris County, Texas, sued county election official S. S. Allwright for the right to vote in the primary. Thurgood Marshall rose in front of the United States Supreme Court to argue that Texas’s Democratic primary system allowed whites to structurally dominate the politics of the one-party South.
It also presaged a discussion of stare decisis, which is a debate that occurs on the Court to this day. [3] Darlene Clark Hine, Black Victory: The Rise And Fall Of The White Primary In Texas 249 (1979).