Nixon v. Condon
Nixon v. Condon is a significant Supreme Court case from 1927 that addressed racial discrimination in the voting process. The case arose when A. L. Nixon, an African American physician, challenged the exclusion of Black voters from Texas Democratic primary elections, which had been implemented through a state law allowing political parties to determine their own voting qualifications. The Democratic Party's restriction to white voters was defended on the grounds that the equal protection clause of the Fourteenth Amendment did not apply to private organizations. However, the Supreme Court, in a 5-4 decision led by Justice Benjamin Cardozo, held that state action was implicated because the state statute granted authority to the party's executive committee to set these voting qualifications. As a result, the Court ruled that this discrimination violated the Fourteenth Amendment. Following the ruling, the Texas legislature repealed the laws governing primary elections, further empowering political parties to regulate their own processes. This case represents a pivotal moment in the fight for African American voting rights and highlights the ongoing struggle against racial disenfranchisement in the United States.
Nixon v. Condon
Date: May 2, 1932
Citation: 286 U.S. 73
Issue: White primaries
Significance: In the second round of the white primary cases, the Supreme Court struck down an exclusion of African Americans from primary elections by a party’s executive committee, holding that the committee was acting as an agent of the state.
In Nixon v. Herndon (1927), the Supreme Court unanimously overturned a law that directly excluded African Americans from voting in the primaries. The Texas legislature responded by authorizing the parties’ executive committees to set qualifications for primary elections. The Democratic committee quickly limited the primaries to whites only. When A. L. Nixon, an African American physician, challenged his exclusion, the Democratic Party asserted that the equal protection clause of the Fourteenth Amendment did not apply to private organizations.
Speaking for a 5-4 majority, Justice Benjamin N. Cardozo ruled narrowly that state action was involved because a state statute had vested the executive committee with its authority to set voting qualifications. The discrimination, therefore, violated the Fourteenth Amendment. The Texas legislature responded by repealing all primary election statutes and giving full control over the primaries to the political parties. This approach to African American disfranchisement would continue until Smith v. Allwright (1944).