GROVEY v. TOWNSEND

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Case Basics
Docket No. 
563
Petitioner 
R. R. Grovey
Respondent 
Townsend
Opinion 
Advocates
(argued the cause for the petitioner)
Term:
Facts of the Case 

R. R. Grovey, an African-American, attempted to vote in the Democratic primary election held on July 28, 1934 and was denied a ballot by the county clerk specifically because of his race. The whites-only restriction of the Texas Democratic Party had been passed by a convention in May 1932. Grovey sued, arguing the restriction violated his rights under the Fifteenth Amendment and the Equal Protection Clause of the Fourteenth Amendment. A Justice Court in Texas denied his claim.

Question 

Did the Democratic Party's refusal to allow Grovey a ballot in the primary election violate his rights under the Fourteenth and Fifteenth Amendments?

Conclusion 

No. In a unanimous opinion authored by Justice Owen Roberts, the Court concluded that the party's restriction had not been authorized or endorsed by the state and therefore was free from the limitations of the Fourteenth and Fifteenth Amendments. The Court had previously ruled in Nixon v. Herndon (1927) and Nixon v. Condon (1932) that the state could not impose such race- based limitations in primaries. However, Justice Roberts noted that the party's rule in Grovey's case could not be limited by the amendments. Justice Roberts wrote that "the Democratic party in that state is a voluntary political association and, by its representatives assembled in convention, has the power to determine who shall be eligible for membership and, as such, eligible to participate in the party's primaries."

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GROVEY v. TOWNSEND. The Oyez Project at IIT Chicago-Kent College of Law. 23 October 2014. <http://www.oyez.org/cases/1901-1939/1934/1934_563>.
GROVEY v. TOWNSEND, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1901-1939/1934/1934_563 (last visited October 23, 2014).
"GROVEY v. TOWNSEND," The Oyez Project at IIT Chicago-Kent College of Law, accessed October 23, 2014, http://www.oyez.org/cases/1901-1939/1934/1934_563.