In the case of Ray v. Blair, 1951, the U.S. Supreme Court ruled that a state has the right to require formal pledges from potential electors in its primary elections as part of their qualifications process for being elected as an elector. The case was brought by Ed Blair who refused to pledge his support for the Democratic Party's presidential and vice-presidential nominees at Alabama’s general election if he were chosen as an elector during primaries. He argued this violated his rights under the First and Fourteenth Amendments but was removed from candidacy by party chairman Gessner T. McCorvey (Ray). The court upheld Alabama's law requiring such a pledge with Justice Reed delivering majority opinion stating it did not violate any constitutional provisions or infringe upon individual freedoms protected by them since political parties have freedom to determine their own rules regarding selection of delegates and candidates.

In the dissenting opinion for Ray v. Blair, Justice Robert H. Jackson argued that political parties are private organizations and should have the right to set their own rules without government interference. He believed that requiring electors to pledge their votes in advance violated this principle of party autonomy. Furthermore, he contended that such a requirement could potentially undermine the Electoral College system by turning electors into mere rubber stamps rather than independent decision-makers as intended by the Founders of Constitution. In his view, while it might be desirable for electors to follow party lines, it was not constitutionally permissible for states to enforce this through legal means.