Nixon v. Herndon

Docket: 117

Court: Supreme Court of the United States; March 21, 1927; Federal Supreme Court; Federal Appellate Court

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An action was brought against Texas election officials for denying a qualified African American voter, the plaintiff, the right to vote in a primary election based on a Texas statute that explicitly barred African Americans from participating in Democratic primaries. The plaintiff sought damages of $5,000, arguing that the statute violated the Fourteenth and Fifteenth Amendments of the U.S. Constitution.

The defendants moved to dismiss the case, claiming it was a political matter outside the court's jurisdiction and that no constitutional violation was evident. The court rejected these arguments, affirming that the denial of voting rights, whether at a primary or general election, constitutes a private wrong for which damages can be recovered.

The central issue was the constitutionality of the Texas statute. The court found the statute to be a clear infringement of the Fourteenth Amendment, which ensures equal protection under the law, especially designed to protect African Americans from discrimination. The court referenced historical precedents affirming that laws cannot discriminate based on color, emphasizing that the Texas statute violated this principle by prohibiting African Americans from voting in primary elections. As such, the court reversed the lower court's judgment.