Breedlove v. Suttles

Background

Appellant is a 28-year-old white man who applied to register to vote in Georgia but had not paid the state's annual one-dollar poll tax covering ages 21 to 60. Georgia's constitution and statutes required payment before registration, exempted the blind and women who did not register, and included an oath stating payment. A Georgia official refused to register him. The state courts dismissed his challenge, and he asked the Court to declare the tax and the registration requirement unconstitutional under the Fourteenth and Nineteenth Amendments.

Reasoning

The Court considered whether Georgia may make poll-tax payment a condition for voter registration and whether age or sex-based exemptions violate federal protections. It explained that poll taxes are a long-established form of taxation and that the equal protection guarantee does not demand absolute uniformity. The Court found the age and sex exemptions reasonable in light of state policies, held that voting is a state-created privilege that may be conditioned, and ruled the Nineteenth Amendment does not prohibit conditioning registration on tax payment. The Court therefore upheld the law and affirmed the lower courts.

Real world impact

This decision leaves Georgia able to require a paid poll-tax receipt before allowing registration for people within the taxed age range. Officials may refuse to administer the registration oath or register applicants who lack proof of payment. Blind people and women who do not register remain exempt under Georgia law. The ruling enforces the state's ability to collect and enforce its poll tax as a prerequisite to voting.