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Once the elective franchise is granted to the electorate, lines may not be drawn which are inconsistent with the Equal Protection Clause of the Fourteenth Amendment. The right of suffrage is subject to the imposition of state standards, which are not discriminatory and which do not contravene any restriction that Congress, acting pursuant to its constitutional powers, has imposed.
Annie Harper, a Virginia citizen and a person of limited means, attempted to register to vote and was asked to pay a poll tax as a condition of registering. She filed a suit against the Virginia Board of Elections in federal district court alleging that her 14th Amendment right of equal protection was being violated by requiring her to pay a tax to vote. A three-judge panel dismissed her case, citing Supreme Court precedence. Harper appealed to the U.S. Supreme Court, which agreed to hear the case.
Does a poll tax on voter registration violate the equal protection rights of a class of citizens?
The Court reversed the order dismissing the state residents' action. The poll tax was an invidious discrimination that violated the Equal Protection Clause of the Fourteenth Amendment. The Court reversed and overruled the prior case to the extent that it sanctioned the tax. It held that a state violated the Equal Protection Clause whenever it made the affluence of the voter or payment of any fee an electoral standard. Voter qualifications had no relation to wealth or to paying or not paying this or any other tax. The Equal Protection Clause prohibited the states from fixing voter qualifications that invidiously discriminated. To introduce wealth or payment of a fee as a measure of a voter's qualifications was to introduce a capricious or irrelevant factor. The degree of the discrimination was irrelevant. As a condition of obtaining a ballot, the requirement of fee paying caused an "invidious" discrimination that ran afoul of the Equal Protection Clause.