Brief Fact Summary. The Defendant, the Jaybird Democratic Association (Defendant), excluded members based on race. The Defendant was held to be engaging in state action for purposes of the Fifteenth Amendment of the United States Constitution (Constitution) because the Defendant had control over the ultimate outcome of the election.
Synopsis of Rule of Law. A private political party that controls the outcome of elections is engaging in state action, thereby making it subject to the Fifteenth Amendment of the Constitution.
Issue. Does a private, successful, political association have to follow the Fifteenth Amendment?
Held. Yes, a private organizations primary election constitutes a public function.
Discussion. For a state to allow what the Defendant wants is to defeat the purpose of the Fifteenth Amendment. It is immaterial that the State does not control the Defendant Association because their candidates are always successful. The Defendant’s primary is the only part of the election that determines who governs the county, which strips blacks of their right to vote for elected officials if they cannot join.