Smith v. Allwright , 321 U.S. 649 (1944), was a very important decision of the United States Supreme Court with regard to voting rights and, by extension, racial desegregation. It overturned the Democratic Party's use of all-white primaries in Texas, and other states where the party used the rule.
Lonnie E. Smith, a black voter in Harris County, Texas, sued county election official S. S. Allwright for the right to vote in a primary election being conducted by the Democratic Party. The law he challenged allowed the party to enforce a rule requiring all voters in its primary to be white. Because the Democratic Party had controlled politics in the South since the late 19th century (see Solid South), most Southern elections were decided by the outcome of the Democratic primary. Representing the NAACP, Thurgood Marshall argued this case in favor of Lonnie E. Smith.
Texas claimed that the Democratic Party was a private organization that could set its own rules of membership. Smith argued that the law in question essentially disfranchised him by denying him the ability to vote in what was the only meaningful election in his jurisdiction. The Court agreed that the restricted primary denied Smith his protection under the law and found in his favor.
Some observers believed the Court's ruling in this case helped prepare for its later ruling in Brown v. Board of Education (1954), in terms of looking at the effect of a practice or law.