Where fundamental rights and liberties are asserted under the Equal Protection Clause of the Fourteenth Amendment, classifications which might invade or restrain them must be closely scrutinized and carefully confined.
Petitioner state residents filed an action against the respondent state voting officials, seeking a declaration that a poll tax, Va. Const. § 173, was unconstitutional as a violation of the Equal Protection Clause. The district court dismissed the actions, relying on an earlier case that had authorized the poll tax, and the state residents sought review. The Court reversed and overruled the prior case to the extent that it sanctioned the tax.
Was the poll tax unconstitutional?
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.