Harper v. Virginia State Board of Elections case brief

Harper v. Virginia State Board of Elections case brief summary
383 U.S. 663 (1966)

CASE SYNOPSIS

Petitioner state residents challenged an order from the United States District Court for the Eastern District of Virginia dismissing their actions against respondent state voting officials, seeking to have a poll tax, Va. Constitutional § 173, declared unconstitutional. They alleged that the poll tax violated the Equal Protection Clause of the Fourteenth Amendment.

CASE FACTS
The state residents filed an action against the voting officials, seeking a declaration that a poll tax, Va. Constitutional § 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.


DISCUSSION

• The Court reversed and overruled the prior case to the extent that it sanctioned the tax. 
• 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.

CONCLUSION
The Court reversed the order dismissing the state residents' action. The poll tax was an invidious discrimination that violated the Equal Protection Clause of the Fourteenth Amendment.