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.
Aliases (1)
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
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|
| discriminationType |
racial discrimination in voting
→
|
| fullName |
Grovey v. Townsend, 295 U.S. 45 (1935)
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|
| 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
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|
| legalArea |
civil rights law
→
constitutional law → election law → |
| legalDoctrine |
state action doctrine
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|
| 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
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|
| timePeriod |
1930s
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|
| votingRightImplication |
limited access of Black citizens to meaningful participation in Democratic Party primaries in Texas
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|
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 |