Facts
- Lonnie E. Smith, a Black citizen and qualified elector in Harris County, Texas, sought to vote in the Texas Democratic primary election held July 27, 1940.
- Election judges, including S. S. Allwright, refused to permit Smith to vote solely because of his race.
- Texas law regulated primary elections and required party primaries as part of the state’s election system for nominating candidates, including for federal offices.
- The Texas Democratic Party, relying on state authorization for party rulemaking, adopted a rule limiting primary participation to white voters.
- Because the Democratic primary effectively determined election outcomes in Texas at the time, exclusion from the primary functioned as disenfranchisement.
Issues
- Whether voting in a primary election that is an integral part of the state’s elective process is a right protected by the Federal Constitution.
- Whether exclusion of Black citizens from a party primary under Texas’s statutory primary system constitutes state action barred by the Fifteenth Amendment.
Decision
- The Supreme Court reversed the judgment for the election judges and overruled Grovey v. Townsend.
- The Court held that the right to vote in a primary that is an integral part of the elective process is a constitutionally protected right.
- The Court concluded that, given Texas’s statutory regulation and incorporation of primaries into its election machinery, the party’s racial exclusion in the Democratic primary constituted state action.
- The Court held that Texas could not, through delegation to a political party, permit race-based exclusion from primary voting consistent with the Fifteenth Amendment.
Legal Principles
- When a state makes primary elections part of the official machinery for selecting public officials, constitutional protections applicable to general elections apply to those primaries.
- Racial exclusion from voting in such a primary is prohibited by the Fifteenth Amendment when it is carried out under authority created, structured, or required by state election law.
- Whether discriminatory exclusion in an election setting constitutes state action is a federal constitutional question not controlled by a state court’s characterization of the conduct as “private.”
- A state may not evade constitutional voting guarantees by delegating control over key parts of the electoral process to political parties that then discriminate on the basis of race.
Conclusion
The Court held that Texas’s exclusion of Black voters from the Democratic primary, implemented within a state-regulated and state-required primary system, amounted to state action that violated the Fifteenth Amendment, invalidating the white primary as a means of racial disenfranchisement.