Nixon v. Condon - 286 U.S. 73, 52 S. Ct. 484 (1932)

Rule:

When agencies of a political party are invested with an authority independent of the will of the association in whose name they undertake to speak, they become to that extent the organs of the state itself, the repositories of official power. They are then the governmental instruments whereby parties are organized and regulated to the end that government itself may be established or continued. What they do in that relation, they must do in submission to the mandates of equality and liberty that bind officials everywhere. They are not acting in matters of merely private concern like the directors or agents of business corporations. They are acting in matters of high public interest, matters intimately connected with the capacity of government to exercise its functions unbrokenly and smoothly.

Facts:

The Texas State Executive Committee of the Democratic Party adopted a resolution limiting participation in primary elections to qualified white democrats. When petitioner, an Afro-American man, presented himself at the polls, the judges refused to give him a ballot or to allow him to vote based solely on his race. Petitioner filed an action for damages, but the district court and the circuit court of appeals dismissed the complaint. Petitioner challenged the decision. 

Issue:

Could the Executive Committee of the Democratic Party adopt a resolution limiting participation in primary elections to qualified white democrats without violating the Fourteenth Amendment? 

Answer:

No.

Conclusion:

The Supreme Court of the United States reversed the decision of the lower courts, holding that whatever power of exclusion was exercised by members of the Committee came to them not as delegates of the party but as the delegates of the state. The Court concluded that as delegates of the state's power, the Committee and the judges discharged their official functions in such a way as to discriminate invidiously between white and black citizens. The Fourteenth Amendment, adopted as it was with special solicitude for the equal protection of members of the black race, placed a duty upon the Court to level by its judgment these barriers of color.