In 1944, in "Smith v. Allwright", the Supreme Court ruled 8–1 against the Texas white primary system. In that case, the Court ruled that the 1923 Texas state law was unconstitutional, because it allowed the state Democratic Party to racially discriminate. After the case, most Southern states ended their selectively inclusive white primaries. They retained other techniques of disenfranchisement, particularly in terms of barriers to voter registration, such as poll taxes and literacy tests. These generally survived legal challenges as they applied to all potential voters, but in practice they were administered in a discriminatory manner by white officials. Although the proportion of Southern blacks registered to vote steadily increased from less than 3% in 1940 to 29% in 1960 and over 40% in 1964, gains were minimal in Mississippi, Alabama, North Louisiana and southern parts of Georgia. The Voting Rights Act of 1965 was intended to address this.