Ray v. Blair
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| Ray v. Blair | ||||||||||||
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| Argued March 31, 1952 Decided April 3, 1952 |
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| Holding | ||||||||||||
| Ray could not be forced to certify Blair if Blair refused to pledge to vote for a certain candidate. In addition, states may now punish faithless electors, because electors are representatives of a state performing a federal function. | ||||||||||||
| Court membership | ||||||||||||
| Chief Justice: Fred M. Vinson Associate Justices: Hugo Black, Stanley Forman Reed, Felix Frankfurter, William O. Douglas, Robert H. Jackson, Harold Hitz Burton, Tom C. Clark, Sherman Minton |
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| Case opinions | ||||||||||||
| Majority by: Reed Joined by: Vinson, Burton, Clark, Minton Dissent by: Jackson Joined by: Douglas Black and Frankfurter took no part in the consideration or decision of the case. |
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| Laws applied | ||||||||||||
| U.S. Const. amends. XII, XIV | ||||||||||||
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 elector candidates, and that it was not a breach of a qualified candidate's 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. Therefore, state electors could be held accountable by their state if they did not vote as instructed. The case was argued on March 31, 1952 and decided on April 3, 1952.
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[edit] Background
Ray, Chairman of the Alabama Executive Committee of the Democratic Party, 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.
[edit] The Decision
The Supreme Court 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.
