The Democratic Party of Texas state convention then adopted a rule banning black voting in primary elections. This revised scheme was upheld in "Grovey v. Townsend" (1935), where the Supreme Court held that this basis for a white primary was constitutional, on the grounds that the political party was a private entity. Another challenge to the Texas white primaries was "Smith v. Allwright" (1944), which overturned "Grovey v. Townsend". In that case the Supreme Court ruled that white primaries as established by Texas were unconstitutional.