Terry v. Adams - Impact

Terry v. Adams was the last of the "white primary cases." White primary laws were developed in the South to exclude black voters from elections. A Texas law limiting primaries to white voters was invalidated in 1927. Texas also passed a law stating that the executive committees of political parties could determine who voted in primaries. The Court invalidated this too. In 1953, when the Court decided that the Jaybird Democratic Association performed a public function and that it violated the Fifteenth Amendment, it ended the practice of white primaries.

Terry v. Adams set a precedent for the Congress to prohibit private racial discrimination under the Fifteenth Amendment. This came into play in later federal legislation, such as the Voting Rights Act of 1965. The case also serves as an example of the "public function" strand of state action doctrine.