321 U.S. 649 (1944)
In July 1940, Lonnie E. Smith, a Negro citizen of the 48th precinct of Harris County, Texas, presented himself to vote in the Democratic Party primary election for nomination of candidates for United States Senator, Representative, Governor, and other state officers.1
Respondents, serving as election and associate election judges of that precinct, refused to furnish him a ballot or permit him to vote. The refusal rested solely on his race and color.
The Democratic Party of Texas had adopted a resolution at its state convention on May 24, 1932, providing that all white citizens of the State qualified to vote under the Constitution and laws of Texas would be eligible to membership in the party and entitled to participate in its deliberations.2 That resolution had remained unamended and supplied the ground for the judges' action.3
Texas statutes in Chapters Twelve and Thirteen of Vernon's Civil Statutes required the Democratic Party to conduct primary elections, directed the election of county and precinct party officers by qualified voters, provided for conventions to select delegates and executive committees, fixed the date and mechanics of primaries, and required certification of party nominees for placement on the general election ballot.4
Smith filed suit in the United States District Court for the Southern District of Texas seeking damages of $5,000 under sections 31 and 43 of Title 8 of the United States Code, together with a declaratory judgment.5 The District Court denied relief.6 The Circuit Court of Appeals affirmed the dismissal on the authority of Grovey v. Townsend.7
The Supreme Court granted certiorari to resolve a claimed inconsistency between Grovey v. Townsend and United States v. Classic.8 Earlier litigation had involved a statutory exclusion of Negroes from Democratic primaries and a later resolution adopted by the party's State Executive Committee, both of which had been invalidated, while the 1932 convention resolution had been sustained as private party action.9
Whether the refusal by election judges to permit a Negro citizen to cast a ballot in a Democratic Party primary election for federal and state offices, based solely on race pursuant to a party convention resolution, violates rights secured by the United States Constitution?10
The Fifteenth Amendment forbids any State from denying or abridging the right of citizens to vote on account of race or color.11 When a State enacts comprehensive statutes that regulate party primaries, require certification of nominees for the general election ballot, and direct the selection of party officials, the party becomes an agency of the State whose racially discriminatory membership rules constitute forbidden state action.12
Yes. In July 1940, Lonnie E. Smith, a Negro citizen of the 48th precinct of Harris County, Texas, presented himself at the polling place to vote in the Democratic primary for nomination of candidates for United States Senator, Representative, Governor, and other state offices. The election and associate election judges refused to furnish him a ballot or permit him to vote. The refusal rested solely on his race and color under the Democratic Party's unamended 1932 state convention resolution that limited membership and participation to white citizens.
Texas statutes in Chapters Twelve and Thirteen of Vernon's Civil Statutes require every party casting over one hundred thousand votes at the preceding general election to hold primaries on a fixed date.13 They select county and precinct officers through elections by qualified voters.14 They convene county and state conventions to choose delegates and executive committees.15 They certify only those primary nominees for placement on the official general election ballot.16 These statutes further prescribe poll tax payment as a condition of primary voting.17 They empower county executive committees to name precinct judges and canvass returns.18 They grant state courts exclusive jurisdiction over primary contests and mandamus actions to enforce party officers' statutory duties.19
The State has integrated the primary into the single instrumentality for choosing public officials.20 It has delegated to the party the power to determine who may participate.21 Therefore, the party's racially exclusionary resolution becomes state action that abridges the constitutional right to vote.22 The Court therefore held that the same constitutional tests applied to general elections must govern primaries when the State has made them an essential step in the electoral process.23
The refusal violated Smith's rights under the Fifteenth Amendment.24
Whether the Democratic Party of Texas functions as an agency of the State when it determines qualifications for participation in primary elections regulated by Texas statutes?25
A political party becomes an agency of the State for Fifteenth Amendment purposes when state statutes direct the election of its officers.26 The statutes require it to conduct primaries on state-prescribed dates and mechanics.27 They make its certified nominees the only candidates eligible for the general election ballot, thereby rendering the party's membership decisions an exercise of delegated state power.28
Yes. The Texas statutes compel the Democratic Party to hold primaries, select its county chairmen and executive committees through elections by qualified voters, and certify nominees who alone may appear on the general election ballot as party candidates.29 No name may be printed on that ballot unless it has been so certified.30 The State further fixes primary dates, polling place restrictions, absentee voting procedures, and the form of the primary test oath.31
When the party applies its white-only membership resolution to exclude Negro citizens from these state-regulated primaries, it performs a state function that the Fifteenth Amendment forbids the State itself to perform.32
The Democratic Party of Texas acted as an agency of the State in excluding Smith from the primary.33
Whether the decision in Grovey v. Townsend should be reexamined in light of the recognition in United States v. Classic that primaries form an integral part of the electoral process for choosing federal officials?34
When a later decision demonstrates that an earlier precedent rested on an incomplete understanding of the constitutional status of primaries, the Court may reexamine and overrule the earlier case. This ensures uniform application of the Fifteenth Amendment across the entire electoral process.35
Yes. United States v. Classic established that when state law makes the primary an integral part of the procedure for selecting federal officials, Congress may regulate it, and the same principle applies to state action under the Fifteenth Amendment.36 Grovey v. Townsend had treated the primary as a purely private party affair whose membership decisions carried no state responsibility, but Classic's recognition of the unitary character of the electoral machinery required reexamination of that premise.37
The statutes of Texas are substantially identical to those of Louisiana in Classic, and therefore the party's exclusion of Negroes from the primary now constitutes state action that Grovey had erroneously insulated from constitutional scrutiny.38
Grovey v. Townsend is overruled.39
Related opinions on this issue
Justice Roberts dissented on the ground that the Court was improperly overruling a carefully considered unanimous decision rendered only nine years earlier on identical facts and statutes.40 He maintained that Classic had not overruled Grovey sub silentio because Classic involved fraud against a concededly qualified voter and never addressed the distinct question of a party's power to define its own membership.41
Roberts warned that the practice of discarding settled precedent without legislative change or new factual distinction would breed public doubt about the stability of constitutional adjudication. It would reduce the Court's decisions to the status of tickets valid only for a single day.