Editing Smith v. Allwright (section)

=== ''Grovey v. Townsend'' ===
In ''Grovey v. Townsend'', the petitioner argued that he was denied a ballot for the Democratic party primary election, even though he is a lawful citizen of the United States of America. The petitioner was going to be absent on the day of the election and demanded an absentee ballot. The petitioner was denied the ballot on the grounds of a statute of the Democratic Convention of Texas which stated:

"Be it resolved that all white citizens of the Texas who are qualified to vote under the Constitution and laws of the state shall be eligible to membership in the Democratic party and as such entitled to participate in its deliberations."

This denial on the grounds of race and color was argued to be a direct and unlawful violation of the Fourteenth and Fifteenth Amendments of the Constitution of the United States of America. Denying a ballot on the basis of the petitioner's race or color is legal under Texas law, but unconstitutional. The Fourteenth Amendment states that no citizen, naturalized or born, shall have their rights infringed by any law, nor shall they be deprived of life, liberty, or property without due process of law, nor deny any citizen equal protection under its laws.

The main question in ''Grovey'' was if a declaration of party membership equated state action. The argument of the respondents was that the resolution of the state convention limiting membership did not limit the participation of black voters, particularly the petitioner. The Supreme Court of the United States ruled that the respondent did not discriminate against the petitioner and therefore did not deny him any Fourteenth or Fifteenth Amendment rights.<ref>{{cite web |title=Grovey v. Townsend, 295 U.S. 45 (1935) |url=https://supreme.justia.com/cases/federal/us/295/45/ |website=Justia |accessdate=7 February 2020}}</ref>