Smith v. Allwright

The ruling overturned the Court's decision, made just nine years earlier in Grovey v. Townsend (1935), that since political parties in Texas were designated as private organizations by the state legislature they could exclude African Americans from membership if they saw fit. Smith v. Allwright is a landmark in the Court's support of civil rights, and in the development of the so-called public function concept. The public function concept holds that essentially public activities, such as elections, must be subject to constitutional scrutiny even if they are managed by private organizations or corporations.