The Democratic Party in several southern states limits participation to whites only in primary elections. The Supreme Court in Grovey v. Townsend (1935) upholds such restrictions, reasoning that political parties are organizations composed of voluntary members acting in a private capacity. The Court reverses itself in Smith v. Allwright (1944), concluding that even though administered by a private party, primary elections are an integral part of the election process and therefore subject to the constraints of the Fifteenth Amendment.