TERRY V. ADAMS 345 U.S. 461 (1953) CASE BRIEF

TERRY V. ADAMS

345 U.S. 461 (1953)

NATURE OF THE CASE: This was a dispute over discrimination against Negroes by a 'private club.'

FACTS: The Jaybird Association or Party was organized in 1889. Its membership was then and always has been limited to white people; they are automatically members if their names appear on the official list of county voters. It has been run like other political parties, with an executive committee named from the county's voting precincts. Expenses of the party are paid by the assessment of candidates for office in its primaries. Candidates for county offices submit their names to the Jaybird Committee in accordance with the normal practice followed by regular political parties all over the country. Advertisements and posters proclaim that these candidates are running subject to the action of the Jaybird primary. While there is no legal compulsion on successful Jaybird candidates to enter Democratic primaries, they have nearly always done so, and, with few exceptions since 1889, have run and won without opposition in the Democratic primaries and the general elections that followed. The party has been the dominant political group in the county since organization, having endorsed every county-wide official elected since 1889. The party excluded Negroes from its primaries on racial grounds. The Jaybirds deny that this exclusion violates the Fifteenth Amendment as their association is not regulated by the State and is not a political party but a voluntary club. The District Court held the Jaybird racial discriminations invalid, and entered judgment accordingly. The Court of Appeals reversed, holding that there was no constitutional or congressional bar to the admitted discriminatory exclusion of Negroes, because Jaybird's primaries were not to any extent state controlled.

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LEGAL ANALYSIS:

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