• Last updated on November 11, 2022

In the first of a series of white primary cases, the Supreme Court overturned a Texas statute that explicitly prohibited African Americans from voting in Democratic Party primaries.

In the one-party states of the South, primary elections were more important than general elections. In 1921, nevertheless, the Supreme Court ruled that Congress had no power to regulate primaries because they were unknown to the Framers of the Constitution and were private affairs of political parties. The Texas legislature used this case as legal justification for enacting the White Primary Law of 1924. A. L. Nixon, an AfricanAfrican Americans;voting rights[voting rights] American physician from El Paso, challenged the law. Speaking for a unanimous Court, Justice Oliver Wendell HolmesHolmes, Oliver Wendell;Nixon v. Herndon[Nixon v. Herndon] held that the law was a “direct and obvious infringement” of the equal protection clause of the Fourteenth Amendment. Holmes’s opinion entirely avoided the issue of the Fifteenth Amendment. The Texas legislature tried to get around the decision by authorizing the executive committees of the Democratic Party to determine qualifications for voting in primaries.African Americans;voting rights[voting rights]White primaries;Nixon v. Herndon[Nixon v. Herndon]African Americans;voting rights[voting rights]

Equal protection clause

Nixon v. Condon

Race and discrimination

Smith v. Allwright

Vote, right to

White primaries

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