White primaries Summary

  • Last updated on November 11, 2022

Legislation in one-party southern states beginning in 1923 that prevented African Americans from voting in primary elections.

In Newberry v. United States[case]Newberry v. United States[Newberry v. United States] (1921), the Supreme Court declared that primaries were not constitutionally protected as elections and could not be controlled by Congress. Although African Americans could not be prevented from voting in federal elections, southern legislatures used Newberry to prohibit African Americans from voting in primaries. In the southern states, which were dominated by the Democratic Party, the only significant competition occurred at the primary level, within the party. Thus, inability to participate in a primary in these states meant effective disfranchisement.Vote, right toVote, right toEqual protection clause

The first challenge to the white primary, Nixon v. Herndon[case]Nixon v. Herndon[Nixon v. Herndon] (1927), resulted in a unanimous decision for the African American plaintiff. Justice Oliver Wendell Holmes held that the Texas white primary law violated the equal protection clause of the Fourteenth Amendment. In Nixon v. Condon[case]Nixon v. Condon[Nixon v. Condon] (1932), the Court invalidated a Texas Democratic Party executive committee order excluding African Americans from voting in primaries. However, in Grovey v. Townsend[case]Grovey v. Townsend[Grovey v. Townsend] (1935), a unanimous Court ruled that white primaries were the elections of a private organization and not forbidden as state action. United States v. Classic[case]Classic, United States v.[Classic, United States v.] (1941), dealing with corrupt voting in Louisiana, held that primaries selecting nominees for federal office were protected. Applying Classic, the Court reversed Grovey in Smith v. Allwright[case]Smith v. Allwright[Smith v. Allwright] (1944). Terry v. Adams[case]Terry v. Adams[Terry v. Adams] (1953) invalidated the preprimary of the Jaybird Democratic Association as a denial of equal protection and removed the final institutional obstacle to African American voting.

Classic, United States v.

Elections

Grandfather clause

Grovey v. Townsend

Nixon v. Condon

Nixon v. Herndon

Poll taxes

Smith v. Allwright

Terry v. Adams

Vote, right to

Voting Rights Act of 1965

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