''Ray v. Blair'', 343 U.S. 214 (1952), is a major decision of the
Supreme Court of the United States
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all Federal tribunals in the United States, U.S. federal court cases, and over Stat ...
. It was a
case
Case or CASE may refer to:
Instances
* Instantiation (disambiguation), a realization of a concept, theme, or design
* Special case, an instance that differs in a certain way from others of the type
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* Case (goods), a package of relate ...
on state political parties' requiring of
presidential electors
In the United States, the Electoral College is the group of presidential electors that is formed every four years for the sole purpose of voting for the president and vice president in the presidential election. This process is described in ...
to pledge to vote for the party's nominees before being certified as electors. It ruled that it is constitutional for states to allow parties to require such a pledge of their candidates for elector, and that it was not a breach of otherwise qualified candidates' rights to be denied this position if they refused the pledge. However, the violation of any pledge a
faithless elector
In the United States Electoral College, a faithless elector is an elector who does not vote for the candidates for U.S. President and U.S. Vice President for whom the elector had pledged to vote, and instead votes for another person for one or ...
made was not at issue. It officially defined state electors as representatives of their respective states, not the
federal government
A federation (also called a federal state) is an entity characterized by a political union, union of partially federated state, self-governing provinces, states, or other regions under a #Federal governments, federal government (federalism) ...
. The case was argued on March 31, 1952 and the Court announced its decision on April 3, 1952; the majority and dissenting opinions were issued on April 15, 1952.
Background
Ben F. Ray, Chairman of the Alabama Executive Committee of the
Democratic Party,
had the duty of certifying elector candidates for
Alabama
Alabama ( ) is a U.S. state, state in the Southeastern United States, Southeastern and Deep South, Deep Southern regions of the United States. It borders Tennessee to the north, Georgia (U.S. state), Georgia to the east, Florida and the Gu ...
's state Democratic
Primaries
Primary elections or primaries are elections held to determine which candidates will run in an upcoming general election. In a partisan primary, a political party selects a candidate. Depending on the state and/or party, there may be an "open pri ...
. Ray refused to certify Edmund Blair as an elector because, while Blair was qualified for the position in all other regards, he had refused to take a pledge that promised, in part, he would support "the nominees of the National Convention of the Democratic Party for President and Vice-President of the United States." While it was not the law that electors had to take such a pledge, the executive committees of the political parties had the statutory right to set the criteria for determining who would be certified as electors in their primaries. Pursuant to this law, the Democratic Party had determined the above-excerpted pledge was a requirement for certification.
A
writ of mandamus
A writ of (; ) is a judicial remedy in the English and American common law system consisting of a court order that commands a government official or entity to perform an act it is legally required to perform as part of its official duties, o ...
was issued to force Ray to certify Blair as an elector, despite the fact that he had not fulfilled the requirements the party had set forth. The
Supreme Court of Alabama
The Supreme Court of Alabama is the highest court in the U.S. state, state of Alabama. The court consists of a Chief Justice, chief justice and eight Associate Justice, associate justices. Each justice is elected in partisan elections for stagge ...
upheld the writ, reasoning, on federal constitutional grounds – specifically the
Twelfth Amendment – that the requirement improperly restricted the freedom of electors to vote their choice in state primaries. Based on the fact that the state supreme court ruling cited the federal
Constitution
A constitution is the aggregate of fundamental principles or established precedents that constitute the legal basis of a polity, organization or other type of entity, and commonly determines how that entity is to be governed.
When these pri ...
, the Supreme Court granted
certiorari
In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of a prerogative writ in England, issued by a superior court to direct that the recor ...
.
The decision
The
Supreme Court
In most legal jurisdictions, a supreme court, also known as a court of last resort, apex court, high (or final) court of appeal, and court of final appeal, is the highest court within the hierarchy of courts. Broadly speaking, the decisions of ...
overturned the decision of the Alabama Supreme Court.
The Court reasoned that, first of all, the federal judiciary has jurisdiction in the matter because, while state electors are not federal officers, they are performing a federal function in assisting to determine the outcome of national elections. The state has the authority to oversee them, and, in doing this, the state acts under the authority from the Federal Constitution.
Further, the Court determined that a state is within its rights to exclude, or to allow parties to exclude, potential electors on the basis of refusing to pledge to support the party's nominees. This is acceptable because it is a method of ensuring that party candidates in the general election are committed to the leadership and philosophy of the party.
Finally, the Supreme Court decided that the
Twelfth Amendment doesn't prevent parties from requiring elector candidates to take a pledge of nominee support. Further, the requirement of a pledge does not deny
equal protection
The Equal Protection Clause is part of the first section of the Fourteenth Amendment to the United States Constitution. The clause, which took effect in 1868, provides "nor shall any State... deny to any person within its jurisdiction the equal pr ...
under the
Fourteenth Amendment. However, it did not address the requirement that electors must vote for their pledged candidate.
The opinion of the Court was delivered by Justice
Reed.
Dissent
Justice Jackson wrote forcefully in his dissent "no one faithful to our history can deny that the plan originally contemplated what is implicit in its text – that electors would be free agents, to exercise an independent and nonpartisan judgment as to the men best qualified for the Nation's highest offices."
See also
*
List of United States Supreme Court cases, volume 343
* ''
Chiafalo v. Washington
''Chiafalo v. Washington'', , was a United States Supreme Court case on the issue of "faithless electors" in the United States Electoral College, Electoral College stemming from the 2016 United States presidential election. The Court ruled unan ...
'' – another Supreme Court case upholding enforcement of electoral pledges
References
External links
*
{{USElectionCourt
1952 in United States case law
United States Supreme Court cases
United States Supreme Court cases of the Vinson Court
United States elections case law
Democratic Party (United States) litigation
United States Supreme Court cases in 1952