The Supreme Court held that excluding African Americans from primaries was an unconstitutional violation of the Fourteenth and Fifteenth Amendments.
In Grovey v. Townsend
By an 8-1 margin, the Court reversed Grovey. Taking a broad view of state action, Justice Stanley F. Reed
The Smith decision is considered one of the major victories of the early Civil Rights movement. It was especially significant in the development of the public function concept, which views many activities as state actions even when performed by private actors. Texas Democrats tried to circumvent Smith by establishing the Jaybird Democratic Association, but the effort was invalidated in Terry v. Adams
Classic, United States v.
Grovey v. Townsend
Race and discrimination
Terry v. Adams