Harman v. Forssenius

Background

Virginia adopted a rule after the Twenty-fourth Amendment that let registered voters qualify for federal elections either by paying a poll tax or by filing a witnessed or notarized certificate of residence each election year. Two class actions in federal court challenged that certificate-or-tax scheme as unconstitutional, and a three-judge District Court declared the certificate requirement invalid and enjoined its enforcement.

Reasoning

The Court looked to the Amendment’s purpose to abolish poll taxes as a prerequisite to federal voting and found Virginia’s statute imposed a real obstacle on those who refused to pay. The certificate demanded annual filing, notarization or witnessing, and a deadline six months before the election—effectively requiring annual re-registration and keeping the poll tax’s disenfranchising effects. The Court held the Twenty-fourth Amendment bars any material requirement imposed solely because a voter refuses to pay a poll tax, so the statute abridged the right to vote and could not be justified as an administrative substitute.

Real world impact

The decision invalidates Virginia’s certificate-or-tax scheme and prevents states from conditioning the federal franchise on poll-tax payment or equivalent burdens. The Court affirmed the District Court’s judgment on Twenty-fourth Amendment grounds and did not address other constitutional claims, so the ruling governs how federal voter qualification rules may be structured.

Dissents or concurrances

Justice Harlan wrote separately, agreeing that the Twenty-fourth Amendment forbids using a state poll tax in determining federal voter qualifications and that abstention was inappropriate.