In the third round of the white primary cases, the Supreme Court accepted the right of political parties acting as private organizations to exclude African Americans from voting in primaries.

In Nixon v. Condon[case]Nixon v. Condon[Nixon v. Condon] (1932), the Supreme Court prohibited racial discrimination in primary elections whenever state action was implicated. The Texas legislature responded by giving the political parties unqualified authority to decide qualifications for membership and voting in primaries. Declaring itself a “private group,” the Democratic Party quickly limited voting rights in primaries to white people only. R. R. Grovey, a black resident of Houston, argued that his exclusion violated his equal protection rights under the Fourteenth Amendment. Speaking for a unanimous Court, Justice Owen J. RobertsRoberts, Owen J.;Grovey v. Townsend[Grovey v. Townsend] found that political parties were voluntary associations and that the racial exclusion was permitted because no state action was involved. Roberts, nevertheless, acknowledged that the state regulated primaries in a variety of other ways. The Grovey decision was reversed in Smith v. Allwright (1944).African Americans;voting rights[voting rights]White primaries;Grovey v. Townsend[Grovey v. Townsend]African Americans;voting rights[voting rights]

Nixon v. Condon

Private discrimination

Race and discrimination

Smith v. Allwright

State action

White primaries