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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.