White primaries
White primaries refer to a practice in the Southern United States where only white voters were allowed to participate in primary elections, effectively disenfranchising African American voters. This system emerged in the early 20th century when the Democratic Party dominated these regions, making primaries the only significant electoral contests. The Supreme Court's ruling in Newberry v. United States (1921) established that primary elections were not constitutionally protected, enabling Southern states to implement laws that excluded African Americans from voting in these critical elections. Subsequent legal challenges, such as Nixon v. Herndon (1927) and Nixon v. Condon (1932), began to dismantle the white primary system by affirming the equal protection rights of African American voters.
However, the issue was not resolved uniformly, as the Grovey v. Townsend (1935) ruling allowed the continuation of white primaries by classifying them as private organizational elections. It wasn't until the landmark case of Smith v. Allwright (1944), which built on the findings of United States v. Classic (1941), that the Supreme Court decisively ruled against the white primary system. Finally, Terry v. Adams (1953) eliminated remaining barriers to African American participation in elections, confirming the significance of equal protection rights in the electoral process. The history of white primaries illustrates the struggle for voting rights and the ongoing impact of systemic racism in American electoral politics.
Subject Terms
White primaries
Description: Legislation in one-party southern states beginning in 1923 that prevented African Americans from voting in primary elections.
Significance: In cases from 1927 to 1953, the Supreme Court declared the white primary to be unconstitutional state action prohibited by the equal protection clause of the Fourteenth Amendment.
In Newberry v. United States (1921), the Supreme Court declared that primaries were not constitutionally protected as elections and could not be controlled by Congress. Although African Americans could not be prevented from voting in federal elections, southern legislatures used Newberry to prohibit African Americans from voting in primaries. In the southern states, which were dominated by the Democratic Party, the only significant competition occurred at the primary level, within the party. Thus, inability to participate in a primary in these states meant effective disfranchisement.
The first challenge to the white primary, Nixon v. Herndon (1927), resulted in a unanimous decision for the African American plaintiff. Justice Oliver Wendell Holmes held that the Texas white primary law violated the equal protection clause of the Fourteenth Amendment. In Nixon v. Condon (1932), the Court invalidated a Texas Democratic Party executive committee order excluding African Americans from voting in primaries. However, in Grovey v. Townsend (1935), a unanimous Court ruled that white primaries were the elections of a private organization and not forbidden as state action. United States v. Classic (1941), dealing with corrupt voting in Louisiana, held that primaries selecting nominees for federal office were protected. Applying Classic, the Court reversed Grovey in Smith v. Allwright (1944). Terry v. Adams (1953) invalidated the preprimary of the Jaybird Democratic Association as a denial of equal protection and removed the final institutional obstacle to African American voting.