Nixon v. Herndon
Encyclopedia
Nixon v. Herndon, 273 U.S. 536 (1927), was a United States
Supreme Court
decision in which the Court struck down a Texas law which forbade blacks from voting in the Texas
Democratic
primary
. Because Texas was a one-party state, the Democratic Party primary was the only competitive process and chance to choose among candidates. This was one of four cases brought to challenge the Texas Democratic Party's all-white primary, all of which were supported by the National Association for the Advancement of Colored People
(NAACP).
, Texas. The defendants, who were magistrates in charge of elections, prevented him from doing so on the basis of a Texas statute 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 federal district court. The district court dismissed the suit, and Nixon appealed to the Supreme Court.
and Fifteenth Amendment
s to the Constitution
. The defendants argued that the Court lacked jurisdiction over the issue, as it was a political question
.
Oliver Wendell Holmes
, rejected the argument that the political question doctrine barred the Court from deciding the case. The argument, said the Court, was "little more than a play upon words." While the injury which the plaintiff alleged "involved political action," his suit "allege[d] and s[ought] to recover for private damage."
The Court then turned to the merits of the suit. It stated that it was unnecessary to discuss whether the statute violated the Fifteenth Amendment, "because it seems to us hard to imagine a more direct and obvious infringement of the Fourteenth." The Court continued: The Court reversed the district court's dismissal of the suit.
Five years later, Dr. Nixon reappeared before the Supreme Court in another suit against the all-white primary. See Nixon v. Condon
(1932).
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
decision in which the Court struck down a Texas law which forbade blacks from voting in the Texas
Texas
Texas is the second largest U.S. state by both area and population, and the largest state by area in the contiguous United States.The name, based on the Caddo word "Tejas" meaning "friends" or "allies", was applied by the Spanish to the Caddo themselves and to the region of their settlement in...
Democratic
Democratic Party (United States)
The Democratic Party is one of two major contemporary political parties in the United States, along with the Republican Party. The party's socially liberal and progressive platform is largely considered center-left in the U.S. political spectrum. The party has the lengthiest record of continuous...
primary
Primary election
A primary election is an election in which party members or voters select candidates for a subsequent election. Primary elections are one means by which a political party nominates candidates for the next general election....
. Because Texas was a one-party state, the Democratic Party primary was the only competitive process and chance to choose among candidates. This was one of four cases brought to challenge the Texas Democratic Party's all-white primary, all of which were supported by the National Association for the Advancement of Colored People
National Association for the Advancement of Colored People
The National Association for the Advancement of Colored People, usually abbreviated as NAACP, is an African-American civil rights organization in the United States, formed in 1909. Its mission is "to ensure the political, educational, social, and economic equality of rights of all persons and to...
(NAACP).
Fact
Dr. L.A. Nixon, a black physician in El Paso, sought to vote in the Democratic Party primary of 1924 in El PasoEl Paso, Texas
El Paso, is a city in and the county seat of El Paso County, Texas, United States, and lies in far West Texas. In the 2010 census, the city had a population of 649,121. It is the sixth largest city in Texas and the 19th largest city in the United States...
, Texas. The defendants, who were magistrates in charge of elections, prevented him from doing so on the basis of a Texas statute 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 federal district court. The district court dismissed the suit, and Nixon appealed to the Supreme Court.
Issue
Nixon argued that the statute violated the FourteenthFourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
and Fifteenth Amendment
Fifteenth Amendment to the United States Constitution
The Fifteenth Amendment to the United States Constitution prohibits each government in the United States from denying a citizen the right to vote based on that citizen's "race, color, or previous condition of servitude"...
s to the Constitution
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
. The defendants argued that the Court lacked jurisdiction over the issue, as it was a political question
Political question
In American Constitutional law, the political question doctrine is closely linked to the concept of justiciability, as it comes down to a question of whether or not the court system is an appropriate forum in which to hear the case. This is because the court system only has authority to hear and...
.
Ruling
The unanimous Court, speaking through JusticeAssociate Justice of the Supreme Court of the United States
Associate Justices of the Supreme Court of the United States are the members of the Supreme Court of the United States other than the Chief Justice of the United States...
Oliver Wendell Holmes
Oliver Wendell Holmes, Jr.
Oliver Wendell Holmes, Jr. was an American jurist who served as an Associate Justice of the Supreme Court of the United States from 1902 to 1932...
, rejected the argument that the political question doctrine barred the Court from deciding the case. The argument, said the Court, was "little more than a play upon words." While the injury which the plaintiff alleged "involved political action," his suit "allege[d] and s[ought] to recover for private damage."
The Court then turned to the merits of the suit. It stated that it was unnecessary to discuss whether the statute violated the Fifteenth Amendment, "because it seems to us hard to imagine a more direct and obvious infringement of the Fourteenth." The Court continued: The Court reversed the district court's dismissal of the suit.
Aftermath
Texas quickly enacted a new provision to continue restrictions on voter participation, granting authority to political parties to determine who should vote in their primaries. Within four months the Executive Committee of the Democratic Party passed a resolution that "all white Democrats ... and none other" be allowed to participate in the approaching primary of 1927.Five years later, Dr. Nixon reappeared before the Supreme Court in another suit against the all-white primary. See Nixon v. Condon
Nixon v. Condon
Nixon v. Condon, 286 U.S. 73 , was a voting rights case decided by the United States Supreme Court, which found the all-white Democratic Party primary in Texas unconstitutional. This was one of four cases brought to challenge the Texas all-white Democratic Party primary...
(1932).