The Texas Democratic Party contended that a political party was a private association that could freely select its membership. This strategy was upheld by the Supreme Court in Grovey v. Townsend (1935). But, in United States v. Classic (1941) the Court conversely held that a primary was an integral part of the electoral process, not a private activity. Inspired by this decision, Thurgood Marshall decided to launch a new attack on the white primary. His client, Lonnie E. Smith, was a black dentist from Houston who had been denied the right to vote in the 1940 primary by Judge S.E. Allwright. On April 3, 1944, in Smith v. Allwright the Supreme Court ruled in favor of Smith, declaring the white primary void as a violation of the Fifteenth Amendment. Indicative of many of the NAACP’s early records, this memorandum reflects Marshall’s grueling travel schedule, as well as his acute sense of humor.