Nixon v. Herndon
| Nixon v. Herndon | |
|---|---|
|
|
| Argued January 4, 1927 Decided March 7, 1927 |
|
| Full case name | L.A. Nixon v. C.C. Herndon and another, Judges of Elections |
| Citations | 273 U.S. 536 (more)
47 S.Ct. 446, 71 L.Ed. 759
|
| Prior history | Error to the District Court of the United States for Western District of Texas |
| Holding | |
| A Texas law prohibiting blacks from voting in the Texas Democratic Party primary violated the Fourteenth Amendment. | |
| Court membership | |
| Case opinions | |
| Majority | Holmes, joined by unanimous |
| Laws applied | |
| U.S. Const. amend. XIV | |
Nixon v. Herndon, 273 U.S. 536 (1927) was a United States Supreme Court decision which struck down a 1923 Texas law forbidding blacks from voting in the Texas Democratic Party primary. Due to the limited amount of Republican Party activity in Texas at the time following the suppression of black voting through poll taxes, the Democratic Party primary was essentially the only competitive process and chance to choose candidates for the Senate, House of Representatives and state offices.
This case was one of four supported by the National Association for the Advancement of Colored People (NAACP) that challenged the Texas Democratic Party's all-white primary, which was finally prohibited in the Supreme Court ruling Smith v. Allwright in 1944.
In 1902 the Texas legislature passed a requirement for a poll tax, which resulted in the suppressed voting by black and Mexican Americans. As voter participation by these groups declined, the Democratic Party became more dominant.
Dr. L.A. Nixon, a black physician in El Paso, Texas and member of the Democratic Party, sought to vote in the Democratic Party primary of 1924 in El Paso. The defendants were magistrates in charge of elections who prevented him from doing so on the basis of the 1923 Statute of Texas which provided that "in no event shall a negro be eligible to participate in a Democratic party primary election held in the State of Texas." Nixon sought an injunction against the statute in the federal district court. The district court dismissed the suit, and Nixon appealed to the United States Supreme Court.
Nixon argued that the statute violated the Fourteenth and Fifteenth Amendments to the Constitution. The defendants argued that the Court lacked jurisdiction over the issue, as it was a political question.
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