Nixon v. Condon

Background

A Black citizen, L. A. Nixon, went to vote in a Texas Democratic primary in 1928 and was turned away by local election judges because the Democratic State Executive Committee had adopted a resolution allowing only white Democrats to participate. That committee action followed a 1927 Texas statute saying parties acting through their State Executive Committee could set their own voter qualifications. Nixon earlier had prevailed in a case striking down a 1923 statute that openly barred Black voters, and he sued again for damages after being refused a ballot; lower federal courts dismissed his claims and the case reached this Court.

Reasoning

The core question was whether the committee’s racial exclusion counted as action by the State and therefore violated the Fourteenth Amendment’s guarantee of equal treatment. The Court held that because the statute placed the power to set qualifications in the State Executive Committee rather than purely in the party, the committee was exercising authority originating in state law. When delegates of the State’s power discriminated by race, that exclusion was state action and unconstitutional. The Court reversed the lower courts and remanded the case for further proceedings. The petitioner’s claim therefore succeeded on the narrow ground presented.

Real world impact

The ruling protects Black voters from being barred from primary elections when a party committee acts under authority given by state law. It prevents state-granted committee resolutions that exclude voters by race from standing. The Court left open broader questions about when parties or their officers are state actors in other contexts, so some issues remain for later cases.

Dissents or concurrances

The dissent argued the committee acted as a private party organ, not a state actor, and that the statutes recognized party autonomy; the dissent would have affirmed the lower courts’ dismissal.