Smith v. Allwright
321 U.S. 649 (1944)
Constitutional Topic Areas:
14th Amendment ‘Equal Protection Clause’, Appellate Jurisdiction, Federalism
Case Facts:
Throughout much of the earlier history of the United States political system, primary election participation was limited to only white males. This was considered legal as political parties were considered private organizations, therefore were allowed to discriminate against whoever they wanted even though the outcome of the election would ultimately affect everyone. In 1923, Lonnie Smith, a black Texas Democratic Party voter in Harris County, was denied voting rights in a primary election for being non-white. Smith then sued the county registrar Allwright for denying his right to vote, arguing a violation of his 14th amendment equal protection rights. Both the district and circuit courts denied Smith’s lawsuit, citing previous Supreme Court precedent set in Grovey v Townsend. The Supreme Court then accepted Smith’s lawsuit for review.
Questions:
1. Are 14th Amendment Equal Protection rights infringed by disallowing non-whites to vote in primary elections?
Holding:
1. Yes
Legal Reasoning: Justice S.F. Reed (8-1)
1. Denying voting rights in primary elections to non-whites violated 14th amendment equal protection rights
2. States allowing political parties to ban non-whites from primary elections equated to state sanctioned discrimination which is unconstitutional
3. Grovey v. Townsend was wrongly decided and will be overturned
Dissent: Justice Roberts
1. The court shouldn’t have overturned Grovey v. Townsend so easily as the court should uphold its reputation for stability
Significance:
Smith overturned Grovey v Townsend. In all subsequent primary elections, voter discrimination was no longer considered constitutional and disadvantaged non-whites could now vote in primaries. The argument of political parties as private organizations under state opinion could not be used in the future to encourage discrimination in primary elections
Reflection:
Although it is now determined states cannot allow disenfranchisement of non-white voters in primary elections, it would not stop states from attempting other methods of voter disenfranchisement such as literacy tests and voter ID laws in the future. Overall, Smith strengthened the power of the federal government
Supreme Court Case Briefs 