Harper v. Virginia Board of Elections

Facts of the case

Question

Conclusion

In a 6–3 decision authored by Justice William Douglas, the Court held the poll tax violated the Equal Protection Clause. Overruling its own precedent in Breedlove v. Suttles (1937), the majority reasoned that the eligibility to vote has no rational connection to the wealth of an individual. Thus, the poll tax could not meet the heightened standard of review applied to restrictions on voting, which is a fundamental right under the Fourteenth Amendment. It is important to note that there was no textual basis for this stark reversal since the Twenty-fourth Amendment applied only to federal elections. This was an example of a situation in which the changing membership of the Court and changing attitudes in society propelled a change in the law. 

Justice John Marshall Harlan II dissented, arguing that the poll tax did pass the rational basis test. Harlan found that the state had a legitimate interest in collecting revenue. He felt that it was reasonable to think that people who were willing to pay to vote would have a greater interest in directing the course of state policy. According to Harlan, this type of classification was no less rational than the literacy test that the Court had upheld in Lassiter v. Northampton County Board of Elections (1959).