Grovey v. Townsend

E73670

Grovey v. Townsend was a 1935 U.S. Supreme Court decision that upheld the Texas Democratic Party’s whites-only primary rule, later repudiated as unconstitutional racial discrimination in voting.


Statements (43)
Predicate Object
instanceOf United States Supreme Court case
civil rights case
voting rights case
affectedGroup Black voters
caseType appeal from a state court decision
citation 295 U.S. 45
constitutionalProvisionInterpreted Fifteenth Amendment to the United States Constitution
Fourteenth Amendment to the United States Constitution
country United States
court Supreme Court of the United States
decisionDate 1935-04-22
defendant Townsend
discriminationType racial discrimination in voting
fullName Grovey v. Townsend, 295 U.S. 45 (1935)
historicalContext Jim Crow era voting restrictions
historicalSignificance part of the line of cases addressing the legality of white primary systems in the American South
holding Texas Democratic Party’s whites-only primary rule did not constitute state action and therefore did not violate the Fourteenth or Fifteenth Amendments
impact contributed to the development of the state action doctrine in election law
temporarily validated the use of party rules to exclude Black voters from primaries
issue constitutionality of whites-only primary elections
racial discrimination in primary voting
jurisdiction State of Texas
United States
languageOfProceedings English
laterCharacterization unconstitutional racial discrimination in voting
legalArea civil rights law
constitutional law
election law
legalDoctrine state action doctrine
outcome Texas Democratic Party’s whites-only primary rule was upheld
overruledBy Smith v. Allwright
overruledByCitation Smith v. Allwright, 321 U.S. 649 (1944)
party R. R. Grovey NERFINISHED
Townsend
plaintiff R. R. Grovey NERFINISHED
precedentStatus later overruled
relatedCase Nixon v. Condon
Nixon v. Herndon
Smith v. Allwright
stateInvolved Texas
subjectMatter Democratic Party primary elections in Texas
timePeriod 1930s
votingRightImplication limited access of Black citizens to meaningful participation in Democratic Party primaries in Texas

Referenced by (2)
Subject (surface form when different) Predicate
Grovey v. Townsend ("Grovey v. Townsend, 295 U.S. 45 (1935)")
fullName
Smith v. Allwright
overruledPrecedent

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