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.
The Defendant is a very successful Texas political organization that operated a lot like a political party. The Defendant’s members are all white. The Defendant Association held pre-primaries and for more than fifty years, the Defendant’s county -wide candidates had invariably been nominated in the Democratic primaries and elected to office. The President of the Defendant Association admitted that the purpose of the party was to exclude blacks from voting and to escape the Fifteenth Amendment’s command that everyone could vote, regardless of race. The Defendant argues that its association is a private club because it was not governed by state laws and did not utilize state elective machinery or funds. Moreover, the Defendant argued that the Fifteenth Amendment constitutional challenge does not apply to their “self-governing voluntary club.” The Plaintiffs, a group of Negro voters (Plaintiffs), brought a class action to determine their rights under 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. Points of Law - for Law School Success
The first has not been granted or secured by the Constitution of the United States; but the last has been. View Full Point of Law
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.