After Reconstruction, southern states began a campaign to disfranchise African American voters in order to eliminate the Republican Party from Southern politics and safeguard white supremacy. Various methods were used, including poll taxes, literacy tests, and violence, but by the 1920s a widely used method of disfranchisement was the white primary. As a political device, legitimized by state statutes, the white primary effectively eliminated African American voters from the electoral process by barring them from primary elections.
In 1923 the intensity of opposition to the white primary increased when Texas abandoned the white primary by party rule and enacted a law that prohibited the participation of African Americans in a Democratic primary election. From the 1920s through the 1950s the NAACP waged a systematic legal campaign against the white primary, arguing that it violated the Fourteenth and Fifteenth Amendments. When the NAACP prevailed in the U.S. Supreme Court, supporters of white primary statutes returned to state legislatures and enacted laws that they thought would pass constitutional muster. The Supreme Court upheld Texas's white primary statute in Grovey v. Townsend (1935), holding that the Democratic Party was a voluntary, private organization that could determine its own membership qualifications.
During the 1940s and 1950s the Supreme Court began to chip away at the legality of the white primary more decisively. In United States v. Classic (1941), for example, the Supreme Court reversed the Townsend precedent, arguing that the Constitution secured the right to vote. In 1944 the Supreme Court further eroded the power of the Texas white primary in Smith v. Allwright, ruling that the state had violated the Constitution by providing ballots at primary elections. This decision largely ended the white primary in Texas. Between 1940 and 1947 the number of registered African American voters in Texas jumped from 30,000 to 100,000. Finally, in Terry v. Adams (1953), the Supreme Court prohibited the legacies of the white primary, insisting that the scope of the Fifteenth Amendment included any election in which public issues are decided or public officials are elected. In the end, the persistence of the NAACP and the willingness of the Supreme Court to create a more democratic society eradicated the white primary as a disfranchisement device.
See also AFRICAN AMERICANS: Civil Rights.
Michael W. Combs University of Nebraska-Lincoln
Combs, Michael W. "The Supreme Court and African Americans: Personnel and Policy Transformations." Howard Law Journal 36 (1993): 139–84.
Key, V. O., Jr. Southern Politics. New York: Vintage Books, 1949.
Woodward, C. Vann. The Strange Career of Jim Crow. New York: Oxford University Press, 1966.