The term white primary referred to a rule which took away the authenticity of legal African American votes - and thus discouraged African American voting. The Democratic Party in some Southern states adopted rules which prohibited African American party membership.[1] The rules were adopted by some southern states after a similar voting exclusion clause, the grandfather clause was judged unconstitutional. The United States Supreme Court ruled the white primary was unconstitutional in the 1944 case Smith v. Allwright.