Nixon v. Condon, 286 U.S. 73 (1932)

This case documents Texas’ first major workaround after Nixon v. Herndon. Rather than openly excluding Black voters by statute, the state delegated authority to the Democratic Party’s executive committee, which then barred black voters from the primary. The Supreme Court struck down that arrangement as well, recognizing that the committee’s authority still came from from state law. This source matters because it demonstrates that disenfranchisement survived due to legal workarounds, but also shows the NAACP’s continued success in framing exclusion as a constitutional issue. Chandler Davidson’s account of Texas politics helps explain why state actors were so determined to preserve white control of the Democratic primary, while Klarman shows how southern officials repeatedly experimented with new methods after setbacks in court. This case marks the shift from explicitly discriminatory laws to a “race-neutral” system.