This case was one of four supported by the National Association for the Advancement of Colored People (NAACP) that challenged the Texas Democratic Party's all-white primary, which was finally prohibited in the Supreme Court ruling Smith v. Allwright in 1944.

It said 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 statute of Texas ... assumes to forbid negroes to take part in a primary election the importance of which we have indicated, discriminating against them by the distinction of color alone.

Texas promptly enacted a new provision to continue restrictions on black voter participation, granting authority to political parties to determine who should vote in their primaries.

It required that otherwise eligible voters pay between $1.50 and $1.75 to register to vote – a lot of money at the time, and a big barrier to the working classes and poor.

The white primary in Texas treated the Democratic Party as a private club whose membership could be restricted to citizens of Anglo heritage.

After numerous legal challenges to successive versions of the law the Legislature had passed to preserve the practice, the U.S. Supreme Court finally and decisively prohibited the white primary in the 1944 case Smith v. Allwright.