Facts
- Texas enacted a statute providing that “in no event shall a negro be eligible to participate in a Democratic party primary election held in the State of Texas.”
- Lawrence A. Nixon, a Black citizen of the United States and Texas and otherwise qualified to vote, sought to vote in a Democratic primary in El Paso County for nominations for federal and state offices.
- Election judges refused to give Nixon a ballot solely because of his race and the statute’s command.
- Nixon sued the election judges in federal district court for damages, alleging unconstitutional denial of his right to vote.
- The district court dismissed the action, accepting arguments that the dispute was “political” and that the statute did not violate the Fourteenth or Fifteenth Amendments.
Issues
- Whether a damages action for wrongful denial of a ballot in a state-regulated primary presents a nonjusticiable “political” question.
- Whether a Texas statute that categorically excludes Black voters from participation in Democratic primaries violates the Fourteenth and/or Fifteenth Amendments.
Decision
- The Supreme Court unanimously reversed the dismissal.
- The Court held the claim was justiciable because it sought redress for private injury (damages) from an unlawful refusal to allow a qualified voter to vote in a state primary.
- The Court held the statute was an “obvious” violation of the Fourteenth Amendment.
- The Court found it unnecessary to decide the Fifteenth Amendment issue in light of the Fourteenth Amendment holding.
Legal Principles
- A qualified voter may maintain an action for damages against election officials who unlawfully deny the voter the right to vote at a state primary election.
- The “political question” label does not bar adjudication where the plaintiff alleges a concrete personal injury and seeks a judicial remedy.
- A state law that explicitly excludes citizens from participation in an election process on the basis of race denies equal protection in violation of the Fourteenth Amendment.
Conclusion
The Court invalidated Texas’s race-based exclusion from Democratic primaries under the Fourteenth Amendment and confirmed that election judges may be liable in damages for unlawfully refusing a qualified voter a ballot in a state-regulated primary.