Nixon v. Herndon
Nixon v. Herndon was a significant Supreme Court case decided in 1927 that addressed the legality of racially discriminatory practices in primary elections, particularly in the South. The backdrop of the case lies in the context of the South's one-party political system, where primary elections held considerable power and influence over political outcomes. A. L. Nixon, an African American physician from El Paso, contested the Texas White Primary Law of 1924, which effectively barred Black voters from participating in the Democratic primary elections.
The Supreme Court, in a unanimous decision delivered by Justice Oliver Wendell Holmes, ruled that the Texas law constituted a "direct and obvious infringement" of the equal protection clause of the Fourteenth Amendment. This ruling highlighted the ongoing struggle for voting rights and the legal challenges faced by African Americans in exercising their civic duties. Although the decision did not address the Fifteenth Amendment, it had lasting implications for future voting rights cases. In response to the ruling, the Texas legislature attempted to circumvent the decision by allowing the Democratic Party's executive committees to set voting qualifications, thereby continuing the fight over racial discrimination in the electoral process. Nixon v. Herndon remains a landmark case in the history of voting rights in the United States.
Nixon v. Herndon
Date: March 7, 1927
Citation: 272 U.S. 536
Issue: White primaries
Significance: In the first of a series of white primary cases, the Supreme Court overturned a Texas statute that explicitly prohibited African Americans from voting in Democratic Party primaries.
In the one-party states of the South, primary elections were more important than general elections. In 1921, nevertheless, the Supreme Court ruled that Congress had no power to regulate primaries because they were unknown to the Framers of the Constitution and were private affairs of political parties. The Texas legislature used this case as legal justification for enacting the White Primary Law of 1924. A. L. Nixon, an African American physician from El Paso, challenged the law. Speaking for a unanimous Court, Justice Oliver Wendell Holmes held that the law was a “direct and obvious infringement” of the equal protection clause of the Fourteenth Amendment. Holmes’s opinion entirely avoided the issue of the Fifteenth Amendment. The Texas legislature tried to get around the decision by authorizing the executive committees of the Democratic Party to determine qualifications for voting in primaries.
