Black History: Special Delivery!!
Smith v. Allwright began in U.S. Federal court in 1940. The case was filed by Dr. Lonnie Smith (1901 – 1971) in Houston, Texas, an African American dentist and civil rights activist. Smith was also an officer in the Houston branch of the NAACP. The legal challenges centered around the practice of excluding blacks from voting in primary elections. At the time, the Democratic Party was the dominant political party in most Southern states. Many Southern white democrats favored segregation and other laws to subjugate black people and prevent them from voting. One such tool that they employed to prevent black people from voting was to declare the Democratic primary elections to be closed to blacks.
The Democratic Party would deem itself to be a private, whites-only organization and then deny black people the opportunity to vote in local primary elections; which came to be known as the “white primary”. The white primary limited the political power and influence of black people. A “primary” election determines which political powers nominees will advance and represent their party in the general election.
Thurgood Marshall (who would later become the first Black U.S. Supreme Court Justice) litigated against the “white party” system in Smith v. Allwright. The case challenged the Texas Democratic Party’s domination of politics in the “one-party” South (One party in the sense that the Democratic Party held the most members and influence). Smith v. Allwright resulted when Dr. Lonnie Smith sued county election official S.S. Allrwright for the right to vote in a Democratic party primary election. Smith’s case sought to challenge the 1923 state law which allowed the Texas Democratic Party to implement a policy requiring all voters in its primary elections to be white; thus disenfranchising Black, Mexican and other voters of color.
At the time the case was filed in 1940, the Texas State NAACP’s legal battle against Texas’s white primary had been ongoing for nearly 20 years. Smith’s case was selected as a test case because of his reputation and credibility within the community. The initial federal court case resulted in a judgement favoring Allwright. The NAACP appealed the case all the way to the Supreme Court. Thurgood Marshall was the lead attorney on the case. In an 8-1 ruling on April 3, 1944, the court found that for states conducting a single party primary, that the primary is “public” rather than private, and therefore protected by the constitution. The Smith v. Allwright case represented the NAACP’s most significant legal victory to date and set an important precedent for the 1954 Brown v. Board of Education case.
The case posited the question of whether the Texas Democratic party’s practice of excluding blacks from voting in primary elections was in violation of the 14th and 15th amendments and therefore unconstitutional. Smith v. Allwright overruled a previous nine-year-old decision in Grovey v. Townsend that upheld race-based restrictions in voting primaries as constitutional. The impact of the Smith v. Allwright case was significant; ushering in the modern civil rights movement. Thurgood Marshall considered Smith v. Allwright his most import case because it established the right of blacks to participate in primary elections, “once and for all”.
Voter registration improved significantly following the Smith v. Allwright ruling. The number of registered Southern black voters increased to between 700,000 to 800,000 by 1948 and then to one million by 1952. Thurgood Marshall approached these gains with caution; reflecting that the work of ending discrimination was not yet finished. History would prove his reflection to accurate; as he would eventually lead a team in litigating the historic Brown v. Board of Education case which rendered segregation in public schools illegal.
The fight to preserve and protect voting rights for people of color continues even to this day.
Check out the video link to learn more about the Smith v. Allwright case: