Snowden v. Hughes et al.
321 U.S. 1 (1944)
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Rule of Law:
The unlawful administration by state officers of a state statute fair on its face, resulting in its unequal application, is not a denial of equal protection under the Fourteenth Amendment unless there is an element of intentional or purposeful discrimination.
Facts:
- Snowden was a candidate in the April 9, 1940, Republican primary election in Illinois for the office of representative in the General Assembly.
- Under the state's proportional representation system, two candidates were to be nominated from the Republican ticket in his district.
- The Canvassing Board of Cook County officially certified that Snowden had received the second-highest number of votes, which entitled him to one of the two Republican nominations.
- This certification was sent to the State Primary Canvassing Board, composed of Hughes, Lewis, and Horner, whose duty was to proclaim the results and issue nomination certificates.
- On April 29, 1940, the State Board issued an official proclamation that designated only the candidate with the highest number of votes as the Republican nominee, willfully and maliciously excluding Snowden.
- This action by the State Board deprived Snowden of the nomination, which was alleged to be tantamount to election to the office.
Procedural Posture:
- Snowden filed a lawsuit in the U.S. District Court for the Northern District of Illinois against Hughes and other members of the State Primary Canvassing Board.
- The defendants filed motions to strike the complaint and dismiss the suit.
- The District Court (a federal trial court) granted the motions and dismissed the suit, holding that the complaint failed to allege a deprivation of a federal constitutional right.
- Snowden, as appellant, appealed the dismissal to the U.S. Court of Appeals for the Seventh Circuit.
- The Court of Appeals affirmed the District Court's dismissal, holding that the officials' actions, being contrary to state law, did not constitute 'state action' under the Fourteenth Amendment.
- The U.S. Supreme Court granted certiorari to review the decision of the Court of Appeals.
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Issue:
Does the unlawful administration of a state election law by state officials, which deprives a candidate of nomination, violate the Equal Protection Clause of the Fourteenth Amendment when there is no allegation of purposeful discrimination against a specific class or person?
Opinions:
Majority - Mr. Chief Justice Stone
No. The unlawful administration of a state statute by state officials does not violate the Equal Protection Clause unless there is an element of intentional or purposeful discrimination. The right to become a candidate for state office is a right of state, not national, citizenship, and is thus not protected by the Privileges and Immunities Clause. Furthermore, the denial of a state political office is not a deprivation of liberty or property under the Due Process Clause. For an Equal Protection claim to succeed based on the unequal application of a facially neutral law, the plaintiff must allege and prove more than just a violation of state law or an erroneous action; they must demonstrate that the officials acted with an 'intentional or purposeful discrimination' against a person or class. Snowden's complaint, despite using terms like 'willful' and 'malicious,' fails to allege any facts showing such a discriminatory purpose, and therefore does not state a claim for denial of equal protection.
Dissenting - Mr. Justice Douglas
Yes. The complaint's allegations of a willful, malicious, and arbitrary conspiracy are sufficient to raise the issue of purposeful discrimination, and the plaintiff should be allowed the opportunity to prove his case. While federal courts should not become supervisors of state elections, a denial of equal protection requires invidious, purposeful discrimination, which can be directed at an individual just as it can be against a class. Snowden's complaint, which charges a conspiracy to willfully and maliciously deny him the nomination, adequately defines the issue of purposeful discrimination to survive a motion to dismiss. He should be allowed the opportunity to show that the law was applied 'with an evil eye and an unequal hand,' which would constitute a violation of the Equal Protection Clause.
Concurring - Mr. Justice Frankfurter
No. The action of the State Canvassing Board was not 'state action' within the meaning of the Fourteenth Amendment because the officials acted in direct defiance of state law. The Fourteenth Amendment prohibits states from denying equal protection, but when state officials openly disobey the clear command of state law, their action cannot be attributed to the state itself unless and until the state's highest court affirms that action. The foundation of Snowden's claim is that the Board disobeyed Illinois law; therefore, the State of Illinois cannot be said to have denied him equal protection. The case is controlled by Barney v. City of New York, and the suit was properly dismissed for this reason.
Analysis:
This case significantly raised the pleading standard for Equal Protection claims arising from the misapplication of state law by officials. By requiring a showing of 'intentional or purposeful discrimination,' the Court prevented the federal judiciary from becoming a forum for resolving any and all errors of state administration. The decision reinforces principles of federalism by limiting federal intervention into state political and administrative matters to cases involving clear, invidious discrimination. This 'purposeful discrimination' standard has become a cornerstone of equal protection jurisprudence, making it substantially more difficult for plaintiffs to succeed in § 1983 actions unless they can provide evidence of discriminatory intent, not just an incorrect or illegal outcome.
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