Smith v. Allwright

by:

Following is the case brief for Smith v. Allwright, 321 U.S. 649 (1944)

Case Summary of Smith v. Allwright:

  • The Democratic Party in the State of Texas only allowed white people to vote in Democratic primaries.
  • Smith, a black Texas voter, sued the county election official, Allwright, for damages of $5,000 for denying him the right to vote in the Democratic primary.
  • The District Court and Court of Appeals denied Smith’s lawsuit, relying on the Supreme Court opinion in Grovey v. Townsend, 295 U.S. 45 (1935).
  • The Supreme Court reversed the lower courts’ decisions and overruled Grovey.  The Court held that a State cannot deny a citizen the ability to vote in primaries or general elections on the basis of race.

Smith v. Allwright Case Brief

Statement of the Facts:

The Texas Democratic Party had a rule in place that only allowed white people to vote in Democratic primaries.  Mr. Smith, a black Texas voter, sued election officials in his county for denying him the right to vote in the Democratic primary in 1940.  He sought $5,000 in damages.  His claim was that the officials violated the Fourteenth and Fifteenth Amendments of the Constitution.

The county election officials argued that Smith did not have a constitutional right to vote in the Democratic primary because the Democratic primary is run by a volunteer party organization, not the State of Texas.  Thus, because the Democratic party is not a governmental organization, it falls outside the reach of the Constitution.

Procedural History:

  • The District Court denied Smith’s case.
  • The Fifth Circuit affirmed the District Court’s decision, finding that it must follow the U.S. Supreme Court case in Grovey v. Townsend, which held that a political party is not an arm of, or agent of, the State for constitutional purposes.
  • The U.S. Supreme Court granted certiorari.

Issues and Holdings:

  1. Can a person be excluded from voting in a primary election on account of race? No.
  2. Can the Supreme Court overrule a previous decision regarding the application of the Constitution if it believes that the previous decision was erroneous? Yes.

Judgment:

The Fifth Circuit Court of Appeals decision is reversed.

Rule of Law or Legal Principle Applied:

  1. It is a violation of the Fourteenth and Fifteenth Amendments to deny a person the right to vote in a primary based on race, and a political party running a primary election acts as an agent of the State for constitutional purposes.
  2. The Supreme Court may overrule a previous decision if it is believed erroneous upon reexamination.

Reasoning:

The Fourteenth and Fifteenth Amendments are clear that no citizen should be denied the right to vote because of race.  Although the county officials in this case argue that the Democratic party is a voluntary, non-governmental organization, the Court believes they are State actors for purposes of primary elections.  The State of Texas regulates primaries.  Thus, the State permitting the Democratic party to allow only white voters participate in the Democratic primary is State action in violation of the Constitution.

The lower courts were correct to follow the Court’s Grovey v. Townsend decision, which held that political parties are not State actors.  However, upon reexamination, the Court believes that Grovey was wrongly decided.  Therefore, expressly overrules that case.  It is desirable to adhere to former Court decisions.  But that principle does not preclude the Court from reexamining a prior ruling.

Concurring and Dissenting Opinions:

Justice Frankfurter concurred in the result with no additional opinion.

Dissenting Opinion (Roberts):

The Court was wrong to overturn the recent decision in Grovey.  The Court’s reputation for stability and consistency is challenged if decisions can so easily be overruled.

Significance:

Smith v. Allwright is a landmark case because it ensured that racial discrimination cannot occur in general or primary elections under the Constitution.  The use of a State-vs.-party distinction could also no longer be used as a pretext to exclude people on the basis of race.  It also presaged a discussion of stare decisis, which is a debate that occurs on the Court to this day.

Student Resources:

Read the Court Opinion