Smith v. Allwright , 321 U.S. 649

Case citation

Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...

 (1944), was a very important decision of the United States Supreme Court

Supreme Court of the United States

The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 with regard to voting rights and, by extension, racial desegregation

Desegregation

Desegregation is the process of ending the separation of two groups usually referring to races. This is most commonly used in reference to the United States. Desegregation was long a focus of the American Civil Rights Movement, both before and after the United States Supreme Court's decision in...

. It overturned the Democratic Party

Democratic Party (United States)

The Democratic Party is one of two major contemporary political parties in the United States, along with the Republican Party. The party's socially liberal and progressive platform is largely considered center-left in the U.S. political spectrum. The party has the lengthiest record of continuous...

's use of all-white primaries in Texas, and other states where the party used the rule.

Background

Lonnie E. Smith, a black voter in Harris County, Texas

Texas

Texas is the second largest U.S. state by both area and population, and the largest state by area in the contiguous United States.The name, based on the Caddo word "Tejas" meaning "friends" or "allies", was applied by the Spanish to the Caddo themselves and to the region of their settlement in...

, sued county election official S. S. Allwright for the right to vote in a primary election

Primary election

A primary election is an election in which party members or voters select candidates for a subsequent election. Primary elections are one means by which a political party nominates candidates for the next general election....

 being conducted by the Democratic Party. The law he challenged allowed the party to enforce a rule requiring all voters in its primary to be white. Because the Democratic Party had controlled politics in the South since the late 19th century, most Southern elections were decided by the outcome of the Democratic primary. Representing the NAACP, Thurgood Marshall

Thurgood Marshall

Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...

 argued this case in favor of Lonnie E. Smith.

Issue

Texas claimed that the Democratic Party was a private organization that could set its own rules of membership. Smith argued that the law in question essentially disfranchised him by denying him the ability to vote in what was the only meaningful election in his jurisdiction.

The Decision

The Court agreed that the restricted primary denied Smith his protection under the law and found in his favor.

The aftermath

Some observers believed the Court's ruling in this case helped prepare for its later ruling in Brown v. Board of Education

Brown v. Board of Education

Brown v. Board of Education of Topeka, 347 U.S. 483 , was a landmark decision of the United States Supreme Court that declared state laws establishing separate public schools for black and white students unconstitutional. The decision overturned the Plessy v. Ferguson decision of 1896 which...

(1954), in terms of looking at the effect of a practice or law.