Grovey v. Townsend, 295 U.S. 45 (1935), was a United States Supreme Court decision that held a reformulation of Texas's white primaries system to be constitutional.
[3] After Texas amended its statute to authorize the political party's state executive committee to set voting qualifications, Nixon sued again; in Nixon v. Condon (1932),[4] the Court again found in his favor on the basis of the Fourteenth Amendment.
[5] The Democratic Party of Texas state convention then adopted a rule banning black voting in primary elections.
The Court unanimously upheld the party's rule as constitutional, distinguishing the discrimination by a private organization from that of the state in the previous primary cases.
[1][6] However, Grovey would be overturned nine years later in Smith v. Allwright (1944), another of the Texas primary cases.