Harper v. Virginia State Board of Elections

Brief Fact Summary. A Virginia law mandated the payment of a poll tax, not to exceed $1.50, in order for citizens to be eligible to vote. The constitutionality of the law was brought into question.

Synopsis of Rule of Law. A State violates the Equal Protection Clause of the United States Constitution (Constitution) by making the affluence of the voter or the payment of a fee an electoral standard.

Facts. A Virginia law mandated the payment of a poll tax, not to exceed $1.50, in order for citizens to be eligible to vote. The constitutionality of the law was brought into question.

Issue. May a State, consistent with the Fourteenth Amendment, precondition the right to vote in an election on the payment of a poll tax?

Held. No. The judgment of the lower court is reversed.
Justice William Douglas (J. Douglas) argued that once the franchise is granted, lines concerning it may not be drawn that are inconsistent with the Equal Protection Clause of the Constitution. The interests a State may pursue (i.e., the legitimate ends) in the context of voting are of setting voter qualifications. There is no relationship between ones wealth or the payment of a fee and ones ability to vote intelligently (i.e., the means to ends relationship is lacking). Moreover, the right to vote is too fundamental to be so burdened.

Dissent. Justice Hugo Black (J. Black) said state poll taxes can reasonably and without invidious purposes, be found to rest on a number of legitimate state interests such as the State’s desire to collect revenue.
Justice John Harlan (J. Harlan) stated there is a rational argument for requiring a poll tax, weeding out those who do not care enough about public affairs to pay $1.50 for the right to vote.

Discussion. The Supreme Court of the United States’ (Supreme Court) primary concern in this case was a distinction made as to which citizens were entitled to a fundamental right – the right to vote. One wonders if the Supreme Court was not also concerned about the statute because it involved a “wealth distinction.” Should ones wealth, as ones race or gender, be regarded as a suspect classification?