Grovey v. Townsend 295 U.S. 45 (1935)
GROVEY v. TOWNSEND 295 U.S. 45 (1935)
Following the decision in nixon v. condon (1932), the Texas state convention of the Democratic party adopted a rule limiting voting in primary elections to whites. Grovey, a black, was refused a primary ballot and sued for damages. The Supreme Court unanimously held that the party's rule did not amount to state action under the fourteenth or fifteenth amendment and thus violated no constitutional rights. Grovey was merely denied membership in a private organization. The Court distinguished Nixon v. Condon as a case in which the party's executive committee had acted under state authorization. Only nine years later, in smith v. allwright (1944), the Court overruled Grovey.
Kenneth L. Karst