Nixon v. Herndon facts for kids
Quick facts for kids Nixon v. Herndon |
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| Argued January 4, 1927 Decided March 7, 1927 |
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| Full case name | L.A. Nixon v. C.C. Herndon and another, Judges of Elections |
| Citations | 273 U.S. 536 (more)
47 S. Ct. 446; 71 L. Ed. 759
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| Prior history | Error to the District Court of the United States for Western District of Texas |
| Holding | |
| A Texas law prohibiting blacks from voting in the Texas Democratic Party primary violated the Fourteenth Amendment. | |
| Court membership | |
| Case opinions | |
| Majority | Holmes, joined by unanimous |
| Laws applied | |
| U.S. Const. amend. XIV | |
Nixon v. Herndon was an important case decided by the U.S. Supreme Court in 1927. This decision said that a 1923 law in Texas was against the rules. This Texas law stopped Black people from voting in the main election, called a primary, for the Democratic Party.
At that time, the Democratic Party was very strong in Texas. Its primary election was often the only real chance to choose who would run for important jobs. These jobs included positions in the U.S. Senate, the House of Representatives, and state offices. This case was one of several supported by the National Association for the Advancement of Colored People (NAACP). They worked to challenge these "all-white" primary elections in Texas. These unfair primary rules were finally stopped by the Supreme Court in the 1944 case Smith v. Allwright.
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Why was the Nixon v. Herndon case important?
This case was important because it challenged a law that directly stopped Black citizens from voting. It was a step in the long fight for equal voting rights for all Americans. The Supreme Court's decision helped show that states could not make laws that discriminated against people based on their race.
What led to the Nixon v. Herndon Supreme Court case?
In 1902, Texas passed a law that made people pay a poll tax to vote. This tax made it harder for Black and Mexican American people to vote. As fewer of these groups voted, the Democratic Party became even more powerful in Texas.
Dr. Lawrence A. Nixon was a Black doctor and a member of the Democratic Party. He lived in El Paso, Texas. In 1924, he tried to vote in the Democratic Party primary election there. However, the election officials stopped him. They used a 1923 Texas law that said "in no event shall a negro be eligible to participate in a Democratic party primary election held in the State of Texas."
Dr. Nixon believed this law was unfair and went against his rights. He decided to take legal action against the election officials. He asked a federal court to stop the law from being used. The first court dismissed his case, meaning they did not agree with him. So, Dr. Nixon appealed his case to the U.S. Supreme Court.
What was the main legal question in the case?
Dr. Nixon argued that the Texas law went against two important parts of the U.S. Constitution: the Fourteenth and Fifteenth Amendments. These amendments are about equal protection and voting rights.
The officials who stopped Dr. Nixon from voting argued that the Court should not even hear the case. They said it was a "political question," meaning it was something for politicians, not judges, to decide.
How did the Supreme Court rule in Nixon v. Herndon?
The Supreme Court, led by Justice Oliver Wendell Holmes, disagreed with the idea that it was a "political question." They said this argument was "little more than a play upon words." Even though the issue involved political actions, Dr. Nixon was seeking to fix a personal harm he suffered.
The Court then looked at the main issue of the case. They said it was not even necessary to discuss the Fifteenth Amendment. This was "because it seems to us hard to imagine a more direct and obvious infringement of the Fourteenth." The Fourteenth Amendment was created to protect Black people from unfair treatment.
The Court explained that the Texas law clearly stopped Black people from voting in important primary elections just because of their skin color. They said that states can make different rules for different groups, but there are limits. It was "too clear for extended argument" that race cannot be used as a reason to take away someone's right to vote in this way.
Because of this, the Supreme Court overturned the lower court's decision. This meant Dr. Nixon's lawsuit could move forward.
What happened after the ruling?
Even after the Supreme Court's decision, Texas tried to find new ways to stop Black citizens from voting. Soon after the ruling, Texas passed a new law. This law gave political parties the power to decide who could vote in their primary elections.
Within four months, the Democratic Party in Texas passed a rule. This rule said that "all white Democrats... and none other" could vote in their upcoming 1927 primary.
Dr. Nixon had to go back to the Supreme Court five years later, in 1932. This new case was called Nixon v. Condon. He was still fighting against the all-white primary system. The Court again ruled against Texas. But Texas kept trying to find new ways to keep the white primary system going.
It was not until the 1944 case of Smith v. Allwright that the Supreme Court finally and clearly banned the white primary system for good.
