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Smith v. Allwright A resolution of the Democratic Party of Texas, a group that the Texas Supreme Court had deemed a "voluntary association," allowed only whites to participate in Democratic primary elections. S.S. Allwright was a county election official; he denied Lonnie E. Smith, a black man, the right to vote in the 1940 Texas Democratic primary. Question Presented Did denying blacks the right to vote in primary elections violate the Fifteenth Amendment? Conclusion The Court overruled its decision in Grovey v. Townsend (1935) and found the restrictions against blacks unconstitutional. Even though the Democratic Party was a voluntary organization, the fact that Texas statutes governed the selection of county-level party leaders, the party conducted primary elections under state statutory authority, and state courts were given exclusive original jurisdiction over contested elections, guaranteed for blacks the right to vote in primaries. Allwright engaged in state action abridging Smith's right to vote because of his race. A state cannot "permit a private organization to practice racial discrimination" in elections, argued Justice Reed. (The Court's decision in this matter was amended on June 12, 1944.) Buckley v. Valeo Facts of the Case In the wake of the Watergate affair, Congress attempted to ferret out corruption in political campaigns by restricting financial contributions to candidates. Among other things, the law set limits on the amount of money an individual could contribute to a single campaign and it required reporting of contributions above a certain threshold amount. The Federal Election Commission was created to enforce the statute Question Presented Did the limits placed on electoral expenditures by the Federal Election Campaign Act of 1971, and related provisions of the Internal Revenue Code of 1954, violate the First Amendment's freedom of speech and association clauses? Conclusion In this complicated case, the Court arrived at two important conclusions. First, it held that restrictions on individual contributions to political campaigns and candidates did not violate the First Amendment since the limitations of the FECA enhance the "integrity of our system of representative democracy" by guarding against unscrupulous practices. Second, the Court found that governmental restriction of independent expenditures in campaigns, the limitation on expenditures by candidates from their own personal or family resources, and the limitation on total campaign expenditures did violate the First Amendment. Since these practices do not necessarily enhance the potential for corruption that individual contributions to candidates do, the Court found that restricting them did not serve a government interest great enough to warrant a curtailment on free speech and association.