United States v. Classic

313 U.S. 299 (1941), argued 7 Apr. 1941, decided 26 May 1941 by vote of 5 to 3; Stone for the Court, Douglas in dissent. Two Supreme Court decisions before World War II allowed white Democrats in the one‐party South to disenfranchise black citizens by denying them primary ballots. Newberry v. United States (1921) concluded that Congress lacked power under Article I, section 4, of the Constitution to regulate party primaries. Grovey v. Townsend (1935) held that a state party convention's exclusion of African‐Americans from primary participation constituted private rather than state action and, therefore, the Fourteenth and Fifteenth Amendments did not apply.

The newly created Civil Rights Section of the Justice Department brought this successful test case, establishing federal authority to redress corruption and discrimination in the state electoral process. The government charged the Louisiana election commissioners with willfully altering and falsely counting congressional primary election ballots in violation of federal civil rights statutes.

The Supreme Court overruled Newberry to hold that Congress's power under Article I, section 4, to regulate “elections” includes the power to regulate primaries when state law makes the primary an integral part of the procedure for choosing candidates for federal office. The Court also reasoned that Article I, section 2, guarantees citizens the right to vote in congressional primaries and to have their votes properly counted; moreover, this right is protected against interference by individual as well as state action. Although Grovey was not mentioned, the reasoning in Classic undercuts the rationale of that decision to make inevitable its overruling in Smith v. Allwright (1944), which held that primary elections for either federal or state office were subject to the Constitution. This also was an early precedent in Screws v. United States (1945) and Monroe v. Pape (1961) for the proposition that an official's misconduct in violation of state law can still be “under color of state law” within the scope of federal civil rights statutes.

See also Race and Racism; White Primary.

— Thomas E. Baker

United States v. Classic
Supreme Court of the United States
Argued April 7, 1941 Decided May 26, 1941
Full case name	United States v. Classic, et al.
Citations	313 U.S. 299 (more) 61 S. Ct. 1031; 85 L. Ed. 1368; 1941 U.S. LEXIS 601
Prior history	On appeal from the District Court of the U.S. for the Eastern District of Louisiana
Holding
U.S. Const. art. 1, Sec. 4 empowers Congress to protect rights of electors in state primary elections; upheld Federal Corrupt Practices Act
Court membership
Chief Justice Charles E. Hughes Associate Justices James C. McReynolds Harlan F. Stone · Owen J. Roberts Hugo Black · Stanley F. Reed Felix Frankfurter · William O. Douglas Frank Murphy
Case opinions
Majority	Stone, joined by Frankfurter, Reed, Roberts; Hughes took no part
Dissent	Douglas, joined by Black, Murphy
Laws applied
U.S. Const. Art. I, Sec. 2; U.S. Const. Art. I, Sec. 4; 18 U.S.C.S. Sec. 51

United States v. Classic 313 U.S. 299 (1941) was a decision by the United States Supreme Court that the United States Constitution empowered Congress to regulate primary elections and political party nominations procedures—but only in cases where state law made primaries and nominations part of the election and/or whenever the primary effectively determined the outcome of the election.

Many observers assumed that the court had already ruled in Newberry v. U.S., 256 U.S. 232 (1921), that primary elections could not be regulated under the powers granted to Congress under Article I, Sec. 4 of the Constitution. But writing for the majority, Justice Harlan Fiske Stone argued that the Newberry court had been deeply divided on the issue and no majority had ruled one way or the other. Utilizing the reasoning by Chief Justice Edward Douglass White and Justice Mahlon Pitney in their concurrent opinions in Newberry, Stone argued that the Constitution's protection of the right to vote cannot be effectively exercised without reaching to primary elections and/or political party nominating procedures.

In a "diffident" dissent, Justice William O. Douglas agreed that the Constutition gives the Congress the right to regulate primaries, but concluded that the U.S. criminal code did not explicitly outlaw the actions in question. "It is not enough for us to find in the vague penumbra of a statute some offense about which Congress could have legislated, and then to particularize it as a crime because it is highly offensive," Douglas wrote. "Sec. 19 does not purport to be an exercise by Congress of its power to regulate primaries."

See also

• List of United States Supreme Court cases, volume 313

External links

• Full text of the decision courtesy of Findlaw.com

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