Smith v. Allwright

Smith v. Allwright, 321 U.S. 649 (1944), was a landmark decision of the United States Supreme Court with regard to voting rights and, by extension, racial desegregation. It overturned the Texas state law that authorized parties to set their internal rules, including the use of white primaries. The court ruled that it was unconstitutional for the state to delegate its authority over elections to parties in order to allow discrimination to be practiced. This ruling affected all other states where the party used the white primary rule. The Democratic Party had effectively excluded minority voter participation by this means, another device for legal disenfranchisement of blacks across the South beginning in the late 19th century. Lonnie E. Smith, a black dentist from the Fifth Ward area of Houston and a voter in Harris County, Texas, sued county election official S. S. Allwright for the right to vote in a primary election being conducted by the Democratic Party. He challenged the 1923 state law that authorized the party to establish its internal rules; the party required all voters in its primary to be white. The Democratic Party had controlled politics in the South since the late 19th century (see Solid South) and the state legislatures of the former Confederacy effectively disenfranchised blacks in the period from 1890 to 1908, by new constitutions and laws raising barriers to voter registration and voting. This crippled the Republican Party in all southern states except Tennessee and North Carolina where exceedingly loyal Unionist Appalachian white Republicanism remained, and resulted in the only competitive elections being held within the Democratic Party primary. Texas had used poll taxes and the white primary to exclude nearly all blacks, Hispanics, and other minorities from voting. Smith v. Allwright questioned whether or not states had the constitutional right to deny voters based on party membership. The Democratic Party of Texas denied Smith the right to vote on the basis of his skin color.