Smith v. Allwright

The Court's attitude toward the disenfranchisement of African Americans in the South began to change in the late 1930s, as appointees of President Franklin D. Roosevelt began to assert their views in its decisions. A case brought by the Civil Rights Division of the U.S. Justice Department to fight corruption in local politics provided the impetus for the Court to reverse its position as defined in Newberry and Grovey.

In 1941 the Civil Rights Division tested the Court's stance on the jurisdiction of the federal judiciary in the case of United States v. Classic. The case involved the willful alteration and false counting of primary election votes by Louisiana election commissioners. By a vote of 5-3, the Court overturned Newberry and ruled that even primary elections must conform to constitutional provisions guaranteeing citizens the right to vote and have their votes accurately and truthfully counted. Although Grovey was not mentioned in the Court's decision, Classic clearly reversed what the Court had determined to be the private nature of political parties, thus leaving the activities of parties liable to scrutiny for constitutionality.