It was the last in a series of court cases addressing the system of white primaries designed to disenfranchise African-American voters in the southern United States.

[8] In United States v. Classic (1941),[9] the Court had ruled that primary elections were an essential part of the electoral process, opening Grovey to review.

Under this reasoning, the Court found that denying non-white voters a ballot in primary elections was a violation of the Fifteenth Amendment, overturning Grovey.

The petitioners, qualified black voters in Fort Bend County including John Terry, Charlie Roberts, Willie Melton, and Arizona Fleming, sued an organization known as the Jaybird Democratic Association, which since 1889 had organized white-only pre-elections for county offices; the winners of these pre-elections invariably won the subsequent official elections.

Justices Hugo Black, William O. Douglas, and Harold H. Burton found that an election that effectively excluded black voters violated the Fifteenth Amendment, while Tom C. Clark, Stanley F. Reed, and Robert H. Jackson found in a concurring opinion that the Jaybirds effectively formed an auxiliary of the Democratic Party, bringing the case within the scope of Smith v. Allwright.