In 1923 Texas enacted the Statute of Texas, which provided that “in no event shall a negro be eligible to participate in a Democratic party primary election held in the State of Texas.” The law was challenged by Dr. L. A. Nixon, a black member of the Democratic Party, in "Nixon v. Herndon" (1927). Nixon was denied a ballot in a Democratic Party primary election in Texas on the basis of the law and sued for damages under federal civil rights laws. The Court found in his favor on the basis of the Fourteenth Amendment, which guarantees “equal protection under the law,” while not discussing his Fifteenth Amendment claim to the franchise.