Ray v. Blair
Encyclopedia
Ray v. Blair, 343 U.S. 214
(1952), is a major decision of the Supreme Court of the United States
. It was a case
on state political parties requiring of presidential electors
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. It officially defined state electors as representatives of their respective states, not the federal government
. The case was argued on March 31, 1952 and decided on April 3, 1952.
, had the duty of certifying elector candidates for Alabama
's state Democratic Primaries
. 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 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 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, the Supreme Court granted certiorari
.
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 unequivocally 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 under the Fourteenth Amendment
.
The opinion of the Court was delivered per curiam by Justice Reed
.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1952), is a major decision of the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
. It was a case
Legal case
A legal case is a dispute between opposing parties resolved by a court, or by some equivalent legal process. A legal case may be either civil or criminal...
on state political parties requiring of presidential electors
United States Electoral College
The Electoral College consists of the electors appointed by each state who formally elect the President and Vice President of the United States. Since 1964, there have been 538 electors in each presidential election...
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. It officially defined state electors as representatives of their respective states, not the federal government
Federal government of the United States
The federal government of the United States is the national government of the constitutional republic of fifty states that is the United States of America. The federal government comprises three distinct branches of government: a legislative, an executive and a judiciary. These branches and...
. The case was argued on March 31, 1952 and decided on April 3, 1952.
Background
Ray, Chairman of the Alabama Executive Committee of the Democratic PartyDemocratic Party (United States)
The Democratic Party is one of two major contemporary political parties in the United States, along with the Republican Party. The party's socially liberal and progressive platform is largely considered center-left in the U.S. political spectrum. The party has the lengthiest record of continuous...
, had the duty of certifying elector candidates for Alabama
Alabama
Alabama is a state located in the southeastern region of the United States. It is bordered by Tennessee to the north, Georgia to the east, Florida and the Gulf of Mexico to the south, and Mississippi to the west. Alabama ranks 30th in total land area and ranks second in the size of its inland...
's state Democratic Primaries
Primary election
A primary election is an election in which party members or voters select candidates for a subsequent election. Primary elections are one means by which a political party nominates candidates for the next general election....
. 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 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 upheld the writ, reasoning, on federal constitutional grounds - specifically the Twelfth Amendment
Twelfth Amendment to the United States Constitution
The Twelfth Amendment to the United States Constitution provides the procedure for electing the President and Vice President. It replaced Article II, Section 1, Clause 3, which provided the original procedure by which the Electoral College functioned. Problems with the original procedure arose in...
- 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, the Supreme Court granted certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
.
The Decision
The Supreme CourtSupreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
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 unequivocally that the Twelfth Amendment
Twelfth Amendment to the United States Constitution
The Twelfth Amendment to the United States Constitution provides the procedure for electing the President and Vice President. It replaced Article II, Section 1, Clause 3, which provided the original procedure by which the Electoral College functioned. Problems with the original procedure arose in...
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 under the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
.
The opinion of the Court was delivered per curiam by Justice Reed
Stanley Forman Reed
Stanley Forman Reed was a noted American attorney who served as United States Solicitor General from 1935 to 1938 and as an Associate Justice of the U.S. Supreme Court from 1938 to 1957. He was the last Supreme Court Justice who did not graduate from law school Stanley Forman Reed (December 31,...
.