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