Grovey v. Townsend
"Grovey v. Townsend" is a significant Supreme Court case from 1935 that addressed racial discrimination in primary elections. The backdrop of the case involves the aftermath of the earlier Nixon v. Condon decision, which had prohibited racial discrimination in primaries when state action was involved. In response, the Texas legislature allowed political parties to set their own membership and voting qualifications, leading the Democratic Party to restrict primary voting rights to white individuals only. R. R. Grovey, an African American citizen, contested this exclusion, claiming it violated his rights under the Fourteenth Amendment's equal protection clause. The Supreme Court, in a unanimous decision led by Justice Owen J. Roberts, ruled that political parties were voluntary organizations and thus could exclude individuals based on race, as long as there was no state action involved. This ruling highlighted the complexities of voting rights and racial discrimination during this era. The decision in "Grovey v. Townsend" was eventually overturned by Smith v. Allwright in 1944, marking a pivotal shift in the legal landscape regarding racial equality in voting. This case remains a critical reference point in discussions about civil rights and the evolution of voting access in the United States.
Grovey v. Townsend
Date: April 1, 1935
Citation: 295 U.S. 45
Issue: White primaries
Significance: In the third round of the white primary cases, the Supreme Court accepted the right of political parties acting as private organizations to exclude African Americans from voting in primaries.
In Nixon v. Condon (1932), the Supreme Court prohibited racial discrimination in primary elections whenever state action was implicated. The Texas legislature responded by giving the political parties unqualified authority to decide qualifications for membership and voting in primaries. Declaring itself a “private group,” the Democratic Party quickly limited voting rights in primaries to white people only. R. R. Grovey, a black resident of Houston, argued that his exclusion violated his equal protection rights under the Fourteenth Amendment. Speaking for a unanimous Court, Justice Owen J. Roberts found that political parties were voluntary associations and that the racial exclusion was permitted because no state action was involved. Roberts, nevertheless, acknowledged that the state regulated primaries in a variety of other ways. The Grovey decision was reversed in Smith v. Allwright (1944).
