Facts
- Virginia required payment of an annual poll tax (up to $1.50) as a prerequisite to registering and voting in state elections.
- Annie E. Harper, a Virginia resident unable to afford the tax, sued on behalf of herself and similarly situated low-income residents.
- Plaintiffs alleged that conditioning the right to vote on payment of the poll tax violated the Equal Protection Clause of the Fourteenth Amendment.
- A three-judge federal district court dismissed the challenge, treating prior Supreme Court precedent upholding poll taxes as controlling.
- Harper appealed directly to the U.S. Supreme Court.
Issues
- Whether the Equal Protection Clause permits a state to condition voting in state elections on payment of a poll tax.
- Whether wealth or payment of a fee may serve as a voter qualification once a state grants the franchise.
- What level of judicial scrutiny applies to classifications that burden the right to vote.
Decision
- The Supreme Court reversed in a 6–3 decision (Justice Douglas for the Court).
- The Court held that Virginia’s poll tax violated the Equal Protection Clause.
- The Court ruled that making voter affluence or payment of any fee an electoral standard is unconstitutional.
- The Court applied heightened review because voting is a fundamental right and the poll tax imposed an invidious classification.
- The Court overruled prior precedent upholding state poll taxes to the extent inconsistent with this holding.
Legal Principles
- Once a state grants the franchise, it may not draw voting qualifications that are inconsistent with the Equal Protection Clause.
- Voting is a fundamental right; classifications that burden it must be closely scrutinized.
- Wealth or fee payment is unrelated to a citizen’s ability to participate intelligently in the electoral process and cannot be used as a voter qualification.
- The state’s legitimate regulatory interest is limited to standards related to voter qualifications; revenue-raising or “responsible voting” rationales do not justify a poll tax.
Conclusion
The Court held that a state may not condition the right to vote in state elections on payment of a poll tax because wealth-based barriers to the franchise violate equal protection, invalidating Virginia’s poll tax and rejecting earlier approval of state poll taxes.