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Terry v. Adams

Supreme Court of the United States · 1953 · Constitutional Law

Constitutional LawFifteenth AmendmentVoting RightsPrimary ElectionsRacial DiscriminationFifteenth Amendmentracial discrimination in votingeffective elective process

Facts

The Jaybird Democratic Association in Fort Bend County, Texas, was organized in 1889 and limited participation to white people, while using county voter qualifications as the basis for membership except for excluding Negroes. It held county-wide primaries for candidates for county offices, and successful Jaybird candidates nearly always then entered and won the Democratic primary and the general election without opposition. The Jaybird president admitted that one purpose of the organization and its May primary schedule was to exclude Negroes from voting. For more than fifty years, the Jaybird choice was the only election result that effectively counted in the county.

Issue

Whether the Fifteenth Amendment forbids Texas from permitting a county political organization, though not formally regulated by the state, to exclude Negroes from its primary when that primary is the only effective part of the elective process for selecting county officials.

Rule

The Fifteenth Amendment and the congressional enactment enforcing it forbid racial discrimination in any election in which public issues are decided or public officials selected. A state violates the Fifteenth Amendment if it permits any device or circumvention within its borders that produces the equivalent of a prohibited racially exclusionary election, even if the state does not control every part of that process. When a privately managed primary becomes an integral and effective part of the elective process, racial exclusion from it is unconstitutional.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Pine Hollow County, Georgia, a private group called the Cedar Committee holds a countywide pre-primary vote for sheriff, tax commissioner, and county clerk. The Committee allows all county voters to participate except Black voters, and for the last 30 years its winners have almost always gone on to win the official party primary and then the general election without meaningful opposition.

A Black voter excluded from the Cedar Committee vote sues. Which is the strongest argument that the exclusion violates the Fifteenth Amendment?

Explanation. The majority treated a formally private pre-primary as unconstitutional when, in practice, it became an integral and effective part of the machinery selecting county officials. The key is not formal state regulation, but whether the device produces the equivalent of a racially exclusionary election for public office. The Fifteenth Amendment is violated when the combined process strips Black voters of meaningful influence in choosing officials.