Grovey v. Townsend facts for kids
Quick facts for kids Grovey v. Townsend |
|
|---|---|
|
|
| Argued March 11, 1935 Decided April 1, 1935 |
|
| Full case name | R. R. Grovey v. Townsend |
| Citations | 295 U.S. 45 (more)
55 S. Ct. 622; 79 L. Ed. 1292
|
| Holding | |
| Democratic Party of Texas private rule banning blacks from voting in primary elections was constitutional. | |
| Court membership | |
| Case opinions | |
| Majority | Roberts, joined by unanimous |
| Laws applied | |
| U.S. Const. amend. XV | |
|
Overruled by
|
|
| Smith v. Allwright (1944) | |
Grovey v. Townsend was a very important decision by the U.S. Supreme Court in 1935. This case was about whether a rule in Texas that stopped Black people from voting in certain elections was fair. The Court said this rule was okay at the time.
This case was one of several called the "Texas primary cases." These cases looked at rules that tried to prevent Black citizens from voting in primary elections.
Contents
What Were White Primaries?
A primary election is when members of a political party choose their candidates. These candidates will then run in the main election. In some parts of the United States, especially in the South, there were "white primaries." These were rules that only allowed white people to vote in the primary elections.
This meant that even if Black citizens could vote in the main election, they couldn't help choose who would run. Since the Democratic Party was very strong in Texas, winning the primary often meant winning the main election. So, white primaries effectively stopped Black citizens from having a say in who governed.
Earlier Cases: Nixon v. Herndon and Nixon v. Condon
Before Grovey v. Townsend, there were two other important cases involving Lawrence A. Nixon. He was a Black doctor from Texas. He tried to vote in a Democratic primary election but was turned away because of his race.
Nixon's First Case: Nixon v. Herndon (1927)
Dr. Nixon sued because he was not allowed to vote. The Supreme Court agreed with him. They said that a Texas law stopping Black people from voting in primaries was against the Fourteenth Amendment. This amendment says that all citizens should have equal protection under the law.
Nixon's Second Case: Nixon v. Condon (1932)
After the first case, Texas changed its law. It allowed political parties to decide who could vote in their primaries. The Democratic Party then made a rule to keep Black people from voting. Dr. Nixon sued again. The Supreme Court once more sided with him. They said that even though the party made the rule, the state had given the party the power to do so. This still counted as the state stopping Black people from voting, which was against the Fourteenth Amendment.
What Happened in Grovey v. Townsend?
After the Nixon cases, the Democratic Party in Texas tried a different approach. This time, the party itself, at its state convention, made a rule. This rule directly said that Black people could not vote in their primary elections. They argued that this was a private rule, not a state law.
R. R. Grovey, a Black resident of Texas, tried to vote in a primary election. He was stopped because of this new party rule. He then sued Townsend, who was a county clerk enforcing the rule. Grovey argued that his civil rights were violated. He said it went against the Fourteenth and Fifteenth Amendments. The Fifteenth Amendment says that the right to vote cannot be denied based on race.
The Supreme Court's Decision
The Supreme Court heard the Grovey v. Townsend case in 1935. This time, the Court made a different decision. All the judges agreed that the Democratic Party's rule was constitutional. They said that the party was a private organization. Because it was a private group, its rules were not the same as state laws. The Court decided that the party's rule did not violate the Fourteenth or Fifteenth Amendments.
This decision meant that political parties could use their own rules to stop Black citizens from voting in primaries. This was a big setback for civil rights.
Grovey v. Townsend Overturned
The decision in Grovey v. Townsend did not last forever. Nine years later, in 1944, the Supreme Court heard another case from Texas. This case was called Smith v. Allwright. In Smith v. Allwright, the Court changed its mind. It decided that white primaries, even those set by political parties, were unconstitutional. The Court said that primary elections were a key part of the voting process. Therefore, they could not be used to discriminate against people based on their race.
This later decision in Smith v. Allwright was a major victory for voting rights. It helped to end the practice of white primaries in the United States.
