elect representatives of their choice to office. The NAACP regularly displayed a black flag stating "A Man Was Lynched Yesterday" from the window of its offices in New York to mark each lynching. It organized the first of the two 1935 New York anti-lynching exhibitions in support of the Costigan-Wagner Bill, having previously widely published an account of the Lynching of Henry Lowry, as An American Lynching, in support of the Dyer Anti-Lynching Bill. In alliance with the American Federation of Labor, the NAACP led the successful fight to prevent the nomination of John Johnston Parker to the Supreme Court, based on his support for denying the vote to blacks and his anti-labor rulings. It organized legal support for the Scottsboro Boys. The NAACP lost most of the internecine battles with the Communist Party and International Labor Defense over the control of those cases and the legal strategy to be pursued in that case. The organization also brought litigation to challenge the "white primary" system in the South. Southern state Democratic parties had created white-only primaries as another way of barring blacks from the political process. Since the Democrats dominated southern states, the primaries were the only competitive contests. In 1944 in Smith v. Allwright, the Supreme Court ruled against the white primary. Although states had to retract legislation related to the white primaries, the legislatures soon came up with new methods to severely limit the franchise for blacks. Legal Defense Fund The board of directors of the NAACP created the Legal Defense Fund in 1939 specifically for tax purposes. It functioned as the NAACP legal department. Intimidated by the Department of the Treasury and the Internal Revenue Service, the Legal and Educational Defense Fund, Inc., became a separate legal entity in 1957, although it was clear that it was to operate in accordance with NAACP policy. After 1961 serious disputes emerged between the two organizations, creating considerable confusion in the eyes and minds of the public. Desegregation By the 1940s, the federal courts were amenable to lawsuits regarding constitutional rights, against which Congressional action was virtually impossible. With the rise of private corporate litigators such as the NAACP to bear the expense, civil suits became the pattern in modern civil rights litigation, and the public face of the Civil Rights Movement. The NAACP's Legal department, headed by Charles Hamilton Houston and Thurgood Marshall, undertook a campaign spanning several decades