Electoral law at the time did not mandate a runoff election, with the losing candidate able to request one. FollowingSweatt v. Painter, which challenged segregation inTexas,Jesse Helms led an advertising campaign throughWRAL to successfully encourage Smith to call for a runoff.[2]
The primary runoff pitched a progressive New Deal Democrat (Graham) against a traditional pro-segregation Democrat (Smith).[3] Graham sought to emphasise his commitments to education and other social programmes, however Smith's relentless campaigning on issues of race ultimately prevailed.[2]
