April 3, 1944
In Smith v. Allwright, the Supreme Court declared the Texas all-white Democratic Party primary elections unconstitutional. Democratic Party primary elections were tantamount to the final election, because the Republican Party was then all but nonexistent in the South. Smith overruled a unanimous nine year old decision in Grovey v. Townsend that held that the Texas Democratic Party’s race-based restrictions on voting in primaries was constitutional because it was not state action as primaries were run by the political parties, thereby making them actions of a private group. The Supreme Court rejected that principle in the decision on this day.