"[1] The case centered on a 1940 Democratic primary election in Louisiana, in which 26-year-old Hale Boggs was running for a seat in the House of Representatives.

(Boggs won the primary by more than 8,000 votes and went on to a long career in Congress, including stints as House majority leader and as a member of the Warren Commission.

)[2] Many observers assumed that the court had already ruled in Newberry v. United States,[3] that primary elections could not be regulated under the powers granted to Congress under Article I, Sec.

Utilizing the reasoning by Chief Justice Edward Douglass White and Justice Mahlon Pitney in their concurrent opinions in Newberry, Stone argued that the Constitution's protection of the right to vote cannot be effectively exercised without reaching to primary elections and/or political party nominating procedures.

[5] In a "diffident" dissent, Justice William O. Douglas agreed that the Constitution gives the Congress the right to regulate primaries, but concluded that the U.S. criminal code did not explicitly outlaw the actions in question.