Nixon v. Condon facts for kids
Quick facts for kids Nixon v. Condon |
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| Argued January 7, 1932 Reargued March 15, 1932 Decided May 2, 1932 |
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| Full case name | L.A. Nixon v. James Condon and another |
| Citations | 286 U.S. 73 (more)
52 S.Ct. 484; 88 A.L.R. 458; 76 L. Ed. 984; 1932 U.S. LEXIS 597
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| Prior history | 34 F.2d 464 (W.D. Tex. 1929), aff'd, 49 F.2d 1012 (5th Cir. 1931), cert. granted, 284 U.S. 601 (1931). |
| Court membership | |
| Case opinions | |
| Majority | Cardozo, joined by Hughes, Brandeis, Stone, Roberts |
| Dissent | McReynolds, joined by Van Devanter, Sutherland, Butler |
| Laws applied | |
| U.S. Const., amend. XIV, Tex. Civ. St. art. 3107 | |
Nixon v. Condon was an important case decided by the United States Supreme Court in 1932. This case was about voting rights in Texas. The Court decided that the rule allowing only white people to vote in the Democratic Party's primary elections was against the U.S. Constitution.
This was one of four cases that challenged the "white primary" system in Texas. The National Association for the Advancement of Colored People (NAACP) supported all these challenges. Later, in 1944, another case called Smith v. Allwright finally made white primaries illegal for good.
Contents
Why the Case Happened
The First Challenge to Voting Rules
The story of Nixon v. Condon began with an earlier case, Nixon v. Herndon, in 1927. In that case, the Supreme Court said that a Texas law stopping Black people from voting in the Democratic Party's primary election was unconstitutional. A primary election is how a political party chooses its candidates for a general election.
Texas Changes the Law
Right after the 1927 decision, the Texas Legislature quickly changed the law. They said it was an emergency. The new law stated that each political party could now decide "in its own way" who could vote or join the party.
Dr. Nixon Tries to Vote Again
Using this new law, the leaders of the Texas Democratic Party made a rule. They said that "all white democrats" could vote in their primary. In 1928, Dr. L. A. Nixon, who was Black, tried to vote in the Democratic primary in El Paso. He was stopped again because of the new rule. So, Dr. Nixon sued the election officials in federal court.
The Main Question for the Court
The people Dr. Nixon sued argued that the Democratic Party was just a private group. They said the party had the right to choose its own members. They claimed that the state of Texas was not involved in this decision. If the state wasn't involved, then the rule about only white people voting couldn't be against the Equal Protection Clause of the Constitution. This clause says that states must treat everyone equally under the law.
The Supreme Court's Decision
The Supreme Court disagreed with the election officials. In a close vote (five justices for Dr. Nixon, four against), the Court explained its decision. The Texas law gave the Democratic Party's leaders the power to exclude people from voting. The Court said that before this law, the party leaders did not have that power.
Because the state of Texas gave this power to the party, the party's actions were considered "state action." This meant the state was involved. Since there was state action, the case was similar to Nixon v. Herndon. That earlier case had already said that state officials could not treat white and Black citizens unfairly. So, the Court ruled that the all-white primary was unconstitutional.
What Happened Next
Impact on Other States
The Supreme Court's decision in Nixon v. Condon affected other Southern states that also had all-white primary elections. These states used similar rules to stop Black citizens from voting.
Texas Responds Again
However, the Democratic Party in Texas found another way to keep Black people from voting. They stopped Black citizens from taking part in the party's meetings where candidates were chosen. This was another way to continue the white primary system.
More Challenges to White Primaries
African Americans continued to challenge these rules. Two more important cases were Grovey v. Townsend (1935) and Smith v. Allwright (1944). Finally, with the Smith v. Allwright case, the Supreme Court clearly and strongly said that white primaries were illegal. This was a big step forward for voting rights in the United States.
