Smith v. Allwright
Smith v. Allwright is a landmark Supreme Court case decided in 1944 that fundamentally challenged the legality of racially discriminatory practices within political party primaries. The case arose when Lonnie Smith, an African American dentist, was denied the right to vote in a Democratic primary in Texas. This denial was rooted in the "white primary" system, which aimed to exclude Black voters from participating in primary elections. Guided by Thurgood Marshall from the NAACP, Smith's legal challenge argued that such practices violated the Fifteenth Amendment, which protects citizens from racial discrimination in voting.
The Supreme Court, in an 8-1 decision, ruled against the Texas Democratic Party, asserting that the party's actions constituted state action due to its operation under state law. This ruling effectively reversed the previous decision in Grovey v. Townsend and marked a significant victory for the Civil Rights movement. It established the principle that states could not endorse discriminatory practices through private party regulations, thus reinforcing the concept of universal voting rights. The implications of Smith v. Allwright extended beyond Texas, prompting further legal challenges against discriminatory voting practices in the American electoral system.
Smith v. Allwright
Date: April 3, 1944
Citation: 321 U.S. 649
Issue: White primaries
Significance: The Supreme Court held that excluding African Americans from primaries was an unconstitutional violation of the Fourteenth and Fifteenth Amendments.
In Grovey v. Townsend (1935), the Supreme Court found that the federal government had no authority over primaries, which were under the direction of private political parties. In United States v. Classic (1941), however, the Court ruled that Congress could ensure the integrity of primaries when they were an integral part of the process for electing members of Congress. Encouraged by Classic, Lonnie Smith, an African American dentist of Houston, sued an election judge for refusing to allow him to vote in a Democratic primary. Thurgood Marshall, counsel for the National Association for the Advancement of Colored People, argued the case on behalf of Smith.
By an 8-1 margin, the Court reversed Grovey. Taking a broad view of state action, Justice Stanley F. Reed reasoned that primaries were “conducted by the party under state statutory authority,” which meant that the party’s discrimination constituted a form of state action. Because the state had established many rules for the primaries, the state had endorsed and participated in the abridgment of the right to vote because of race, which violated the Fifteenth Amendment. Justice Owen J. Roberts, the author of the majority opinion in Grovey, dissented.
The Smith decision is considered one of the major victories of the early Civil Rights movement. It was especially significant in the development of the public function concept, which views many activities as state actions even when performed by private actors. Texas Democrats tried to circumvent Smith by establishing the Jaybird Democratic Association, but the effort was invalidated in Terry v. Adams (1953), the last of the white primary cases.