Module 37: The Twenty-Fourth Amendment

How We Got Here: A Tax on the Ballot

The Constitution of 1787 left the question of who may vote mostly to the States. Article I, section 2 says the people who elect the House of Representatives "shall have the Qualifications requisite for Electors of the most numerous Branch of the State Legislature," which means whatever each State decides for its own lower house.¹ For most of the nineteenth century that included property tests, race tests, sex tests and, in time, a charge for the ballot itself.

Taxing heads is old. "Levy by the poll," the Supreme Court said in 1966, "is an old familiar form of taxation."² What was new after Reconstruction was making the receipt of that tax a condition of voting. The Constitution Annotated puts it plainly: property qualifications reach back to colonial days, but the poll tax as a voting qualification was set up in eleven Southern States after Reconstruction ended.³ A history of the amendment published by HISTORY says all eleven former Confederate States adopted one between 1870 and 1902, and reports that at the time of passage the charges ran, in today's money, from $22.66 in Tennessee to $65.24 in Mississippi.⁴

Historians weigh the tax's effect differently. The same account quotes Keith Finley of Southeastern Louisiana University for the view that by the late 1940s "everyone recognized that the literacy test, not the poll tax, was the key stumbling block to Black suffrage."⁴ That is a fair caution against crediting one device with everything. The tax was one piece of a set of devices. It also took money from voters of every race who had little of it, and it came due in a way that was easy to miss: in several States the bill had to be paid months before the election and, for those who fell behind, the arrears piled up.

The slow campaign in Congress

Congress first took up the question in 1939 and kept at it for twenty-three years.³ A statute did not look safe. The federal courts had already turned away challenges to poll taxes on several grounds. The Supreme Court unanimously upheld Georgia's tax in Breedlove v. Suttles on December 6, 1937; the Fourth Circuit rejected a challenge to Virginia's in Saunders v. Wilkins (1945); and in Butler v. Thompson the Court affirmed another Virginia ruling in 1951.³² A House report in 1962 called the tax "an obstacle to the proper exercise of a citizen's franchise" and said Congress thought a constitutional amendment was needed because those precedents stood in the way.³

By 1962 the problem had shrunk. Only five States still used the tax: Alabama, Arkansas, Mississippi, Texas and Virginia.⁴ That shrinkage helps explain both why the amendment could pass by a wide margin and why some of its opponents argued the States would finish the job on their own.

The Text

The Twenty-fourth Amendment has two sections and was never amended.

Section 1. The right of citizens of the United States to vote in any primary or other election for President or Vice President, for electors for President or Vice President, or for Senator or Representative in Congress, shall not be denied or abridged by the United States or any State by reason of failure to pay any poll tax or other tax.

Section 2. The Congress shall have power to enforce this article by appropriate legislation.

U.S. Const. amend. XXIV (ratified January 23, 1964), National Archives transcription

Take the clauses one at a time, because each one limits the amendment.

"The right of citizens of the United States to vote." The amendment does not create a general right to vote. It protects a right that already exists under state law and the Constitution, and it names one thing that may not take it away.

"In any primary or other election." Primaries are covered by name. That matters because in much of the South the Democratic primary was the only real contest, so a tax on the general election ballot alone would have done little.

"For President or Vice President, for electors for President or Vice President, or for Senator or Representative in Congress." These are federal offices. The amendment says nothing about a mayor, a school board, a county commission or a state legislature. For those elections the poll tax fell under a different provision, the Equal Protection Clause, in Harper two years later.

"Denied or abridged by the United States or any State." The verbs come from the Fifteenth Amendment (race) and the Nineteenth (sex), and the Twenty-sixth later borrowed them for age. "Abridged" is the wider word. A State does not have to turn a voter away to abridge the right. It can make voting harder for the people who will not or cannot pay.

"By reason of failure to pay any poll tax or other tax." "Other tax" closes the obvious workaround. A property tax, an income tax or a tax by another name cannot be made a condition either. Whether a particular payment counts as a "tax" at all is the live question, and the modern cases turn on it (see "What Counts as an Other Tax" below).

Section 2. Congress may enforce the article "by appropriate legislation." Congress used this power and its other election powers in section 10 of the Voting Rights Act of 1965.⁶

Passage in Congress, 1962

Holland's route was clever, and it is worth following because it shows how a few senators can force a vote that the committee system would otherwise bury. According to HISTORY, the Judiciary Committee under Senator James Eastland of Mississippi was where civil rights bills went to die. Holland instead waited for a harmless bill on the Senate floor, one making Alexander Hamilton's home, the Grange, a national monument, and offered his anti-poll-tax text as a substitute. Majority Leader Mike Mansfield opened debate on March 14, 1962 and told the Senate that Holland would move the substitute.⁴

The Southern bloc objected to the procedure first and the substance second. Senator Lister Hill of Alabama called the move "unusual and extraordinary and almost unprecedented." Senator John Stennis of Mississippi said voting was "a privilege; it [was] not a right," as HISTORY reports. The same account says President Kennedy chose to ask for a constitutional amendment instead of a statute because an amendment would remove the argument that Congress was exceeding its powers.⁴ After a filibuster of about ten days, the Senate passed the resolution 77 to 16.⁴ The Grange bill itself was handled separately, and Kennedy signed it on May 2.⁴

The House took the Senate's measure, S.J. Res. 29, on August 27, 1962, and passed it 295 to 86.⁷ Article V requires two-thirds of both Houses, and 295 of the 381 members voting is about 77 percent, so the margin was not close.⁷ The resolution went to the States the next day.⁸ It carried no deadline for ratification. Two years later that detail would have been a footnote. By the 1980s and 1990s it had become the center of a larger story (see Module 40, The Twenty-Seventh Amendment).

Ratification: Thirty-Eight States in Fourteen Months

Illinois ratified first, on November 14, 1962. New Jersey followed on December 3. Then the legislatures that met in early 1963 did most of the work: Oregon on January 25, Montana on January 28, West Virginia on February 1, and so on, with ten more States by the end of February and a tail of ratifications that ran until Kentucky's on June 27, 1963.⁸ Mississippi, one of the five poll tax States, voted to reject the amendment on December 20, 1962.⁸ Maine ratified on January 16, 1964, and South Dakota on January 23, 1964. South Dakota was the thirty-eighth.⁸ The Administrator of General Services declared the amendment ratified in a proclamation dated February 4, 1964.⁸

The chart in the Numbers section shows how the ratifications bunched in the first quarter of 1963. Legislative calendars explain that: most State legislatures meet in the winter and early spring, so an amendment sent to them in late August needs to wait for them to convene.

The late ratifications

Three of the five poll tax States ratified after the amendment took effect, long after it mattered in practice. Virginia ratified on February 25, 1977. Alabama ratified on September 26, 2002, and Texas on May 22, 2009, forty-five years after the amendment became part of the Constitution. North Carolina, which was not one of the five, also ratified late, on May 3, 1989.⁸ Mississippi's 1962 vote was a rejection, and the House Manual does not list a later ratification for it. These votes carry no legal weight, since the amendment was already in force, but they do show how a State's view of its own history can change.

Harman v. Forssenius (1965): The Workaround Fails

Virginia had to respond to the amendment for federal elections, and it did so with a device. The legislature stopped requiring the poll tax as a flat prerequisite for voting in federal elections. In its place, a federal voter could either pay the usual tax or file a witnessed or notarized certificate of residence at least six months before the election.⁹ The tax was still there for anyone who did not want to file the certificate, and for those voters nothing changed.

The Supreme Court heard argument on March 1 and 2, 1965 and decided the case on April 27. It was the Court's first look at the new amendment, and Chief Justice Warren wrote that "we are called upon in this case to construe, for the first time, the Twenty-fourth Amendment." The opinion held that Virginia could not impose a penalty on people who chose to exercise a federally guaranteed right: "It has long been established that a State may not impose a penalty upon those who exercise a right guaranteed by the Constitution."⁹ Because the certificate was a "material requirement" imposed only on voters who refused to pay the tax, the Court held it conflicted with the amendment. The Constitution Annotated notes that the Court held this unanimously.⁶

The most useful sentence in Harman is borrowed from an earlier voting case. The amendment, the Court said, "nullifies sophisticated as well as simple-minded modes" of impairing the right, a line from Lane v. Wilson (1939) and one that has reached beyond poll taxes.⁹ A State that wants to reach the same result by a different route has to show the route is not a tax by another name.

Harper v. Virginia State Board of Elections (1966): Poll Taxes in State Elections

The amendment covers only federal elections. That left Virginia's $1.50 poll tax in place for state and local ones, and a group of Virginia residents sued to strike it down. A three-judge district court dismissed the complaint because it felt bound by Breedlove v. Suttles.² The Supreme Court reversed on March 24, 1966, by a vote of 6 to 3. Justice Douglas wrote for the Court. Justice Black dissented, and Justice Harlan dissented in an opinion joined by Justice Stewart.²

The majority

The Court did not rest on the Twenty-fourth Amendment. It rested on the Fourteenth. Voting, Douglas wrote, is a "fundamental political right, because preservative of all rights," quoting Yick Wo v. Hopkins (1886), and "any alleged infringement of the right of citizens to vote must be carefully and meticulously scrutinized," quoting Reynolds v. Sims (1964).² Then came the line that the case is known for:

"Wealth, like race, creed, or color, is not germane to one's ability to participate intelligently in the electoral process. Lines drawn on the basis of wealth or property, like those of race . . . are traditionally disfavored."

Harper v. Virginia State Board of Elections, 383 U.S. 663, 668 (1966) (Douglas, J.)

Virginia argued that States charge fees for driver's licenses and many other things, so a fee for voting was just another fee. The Court answered that "the interest of the State, when it comes to voting, is limited to the power to fix qualifications." It added: "We say the same whether the citizen, otherwise qualified to vote, has $1.50 in his pocket or nothing at all, pays the fee or fails to pay it."² On the older cases, the Court was brief: "Levy 'by the poll' ... is an old familiar form of taxation; and we say nothing to impair its validity so long as it is not made a condition to the exercise of the franchise. ... To that extent the Breedlove case is overruled."²

The opinion also made an argument about method. "Notions of what constitutes equal treatment for purposes of the Equal Protection Clause do change," Douglas wrote, and the Court gave Plessy v. Ferguson as its example of a time when the Court's notions had been wrong.²

The dissents

Justice Black had joined the unanimous Breedlove Court a few weeks after taking his seat in 1937, and he stayed with it. The Constitution, he wrote, "has not been amended in the only way it could constitutionally have been, that is, as provided in Article V," since then. In his view the Court had used its power to "amend" the meaning of the Equal Protection Clause, a power he said the Constitution gave to Congress and the States.²

Justice Harlan agreed that poll taxes were a poor policy and said so. His point was about who should end them. State poll taxes were "already totally proscribed by the Twenty-Fourth Amendment with respect to federal elections and abolished by the States themselves in all but four States with respect to state elections," so the Court's decision was "perhaps in itself not of great moment." The concern was that "the coup de grace has been administered by this Court instead of being left to the affected States or to the federal political process." Harlan would have applied the ordinary rational-basis test to the tax.² He also pointed to the quick ratification of the Twenty-fourth Amendment as proof that the democratic process was working.²

Reading the two sides fairly

The disagreement is still the one that runs through voting and equal protection cases. One reading holds that the Fourteenth Amendment's meaning was fixed by the understanding at ratification in 1868, and that when the people wanted to bar a charge on voting they said so by amendment, as they did in 1964 for federal elections. The other reading holds that the Equal Protection Clause states a principle that courts apply to new facts, and that a fee on voting violates the principle no matter when the fee was invented. Harper chose the second reading by a 6 to 3 vote, and its result is settled law. The method it used, a stricter look at laws that touch voting, is still cited and still argued over.

After Harper: The Voting Rights Act and the End of the Tax

Congress did not wait for the courts. Section 10 of the Voting Rights Act of 1965 declared that poll taxes could be used to discriminate and directed the Attorney General to bring suits against States that still used them.⁶ Suits followed against Texas and Alabama. A three-judge federal court in Texas declared the Texas poll tax unconstitutional on February 9, 1966, as Justice Harlan noted, and the Supreme Court affirmed on other grounds in United States v. Texas, 384 U.S. 155 (1966).⁶² A three-judge court in Alabama did the same in United States v. Alabama, 252 F. Supp. 95 (M.D. Ala. 1966).⁶

Harlan footnoted that the Texas tax had been $1.75 a year and that, by his count, nearly every State had already given up property and poll-tax qualifications.² By the end of 1966 the poll tax as a condition of voting was gone from state and federal elections alike. The amendment did its work first for federal elections. The Equal Protection Clause and the Voting Rights Act finished the rest.

What Counts as an Other Tax: Modern Questions

For decades after 1966 the amendment sat quiet. Two modern disputes have brought it back into court, and both ask where a government charge stops being a "tax."

Fees and costs in a criminal sentence: Jones v. Governor of Florida (2020)

In 2018 Florida voters approved a state constitutional amendment restoring voting rights to people with felony convictions who complete "all terms of their sentence." The legislature then defined that phrase to include fines, fees and restitution. Some of the affected people argued that court fees and costs were an "other tax," so that denying the vote for failure to pay them violated the Twenty-fourth Amendment. The en banc Eleventh Circuit rejected the argument on September 11, 2020.¹⁰

The court gave two separate reasons. First, "the term 'tax' is a broad one, but it does not cover all monetary exactions imposed by the government"; the court wrote that "if a government exaction is a penalty, it is not a tax," and it held that "fees and costs imposed in a criminal sentence are not taxes under the Twenty-Fourth Amendment." The people challenging the law did not argue that fines and restitution were taxes, and the court said they are "not taxes under any fair reading of that term."¹⁰ Second, even if the fees were taxes, Florida had not denied the vote "by reason of" the failure to pay them, because the condition was completing a sentence that included the money terms.¹⁰ Part of the opinion drew only two votes in its reasoning, so a careful reader should read the part that commanded a majority and the part that did not as separate.¹⁰

The decision binds courts in Alabama, Florida and Georgia. Courts elsewhere, including in the Ninth Circuit that covers Idaho, are not bound by it. This lesson did not find an Idaho or Ninth Circuit decision on the point.¹¹

The cost of getting an ID: Crawford and the voter ID cases

When States began requiring photo identification at the polls, challengers argued that if a voter had to pay for the underlying documents, the requirement worked like a poll tax. In Crawford v. Marion County Election Board (2008), a lead opinion by Justice Stevens said Harper stood for the rule that a State "violates the Equal Protection Clause of the Fourteenth Amendment whenever it makes the affluence of the voter or payment of any fee an electoral standard," then explained that later cases, beginning with Anderson v. Celebrezze, ask the court to weigh the burden against the State's interests, and upheld Indiana's law against a facial challenge.¹² The ruling came on the Equal Protection claim, and no Justice treated the Twenty-fourth Amendment as the source of the rule. This lesson could not confirm any decision that has held a voter ID fee to violate the Twenty-fourth Amendment.

The practical consequence for a State that requires ID is a design question: does it give a voter with no listed ID a way to vote that costs nothing? In Idaho, the Secretary of State says a registered voter may sign a Personal Identification Affidavit in place of photo ID.¹³

Myths and Misreadings

• "The Twenty-fourth Amendment ended all poll taxes." It ended them for federal elections. Poll taxes in state and local elections ended through Harper, which relied on the Fourteenth Amendment, and through suits the Attorney General brought under the Voting Rights Act.⁶
• "The amendment banned literacy tests." It did not. Literacy tests were addressed by the Voting Rights Act of 1965 and its extensions, and the Court upheld the 1970 five-year ban in Oregon v. Mitchell (see Module 39, The Twenty-Sixth Amendment).
• "Any fee tied to voting is unconstitutional." The Court's rule is narrower. A fee cannot be a condition of voting. The Twenty-fourth Amendment reaches taxes, and the Eleventh Circuit has held that a criminal sentence's fees and costs are penalties, not taxes.¹⁰²
• "The Court overruled Breedlove v. Suttles entirely." Harper said "to that extent the Breedlove case is overruled," meaning to the extent it allowed a poll tax as a prerequisite of voting. The Court said it had nothing to say against taxing by the head so long as the tax was not a condition of the franchise.²
• "The amendment was passed by Southern senators who wanted the tax gone." The Senate vote was 77 to 16, and its sponsor's motives, as reported, were mixed.⁴ The vote shows broad support. It does not show a single motive.

Questions People Ask

Could a State bring back a poll tax if it called it something else? Not for a federal election. "Any poll tax or other tax" and the Harman line about "sophisticated as well as simple-minded modes" would apply, and Harper would apply to state and local elections.⁹²

Can a State charge a fee for a candidate to get on the ballot? That is a different question about ballot access, and it falls under the Equal Protection Clause and the First Amendment, not the Twenty-fourth Amendment, which speaks of the right of citizens "to vote." This lesson did not review the ballot-access cases.

Does the amendment cover a tax on absentee ballot postage or the cost of a notary? The text bars denial of the vote "by reason of failure to pay" a tax. Courts decide whether a given cost is a tax or an incidental expense of voting, and the answer has gone differently depending on the cost and the claim.¹²

Why does the amendment mention primaries? Because in 1962 the primary was where many elections were decided in the States that used the tax.⁴

Who enforces it? Voters can sue. Congress has authority under Section 2, and section 10 of the Voting Rights Act of 1965 gave the Attorney General suit power over poll taxes.⁶

Landmark Cases

Each case was checked against the opinion text or the Constitution Annotated entry cited in the footnotes.

The Idaho Connection

Ratification. Idaho ratified the Twenty-fourth Amendment on March 8, 1963, according to the House Manual's list of ratification dates. Counting in the order the Manual lists them, Idaho was the twentieth of the thirty-eight States whose ratifications completed the amendment.⁸ Idaho ratified after North Dakota (March 7) and before Washington (March 14).

The Idaho Constitution. Article VI, section 2 sets the qualifications of electors: a citizen of the United States, eighteen years old, who has resided in the State and the county for the period provided by law, and is registered as provided by law.¹⁴ Idaho Code section 34-402 repeats those terms and adds thirty days of residence in the State and the county.¹⁵ Neither mentions a tax. Article VI, section 4 allows the legislature to "prescribe qualifications, limitations, and conditions for the right of suffrage, additional to those prescribed in this article," but "shall never annul any of the provisions in this article."¹⁴ A new condition the legislature adds is still bound by the federal Constitution, including the Twenty-fourth Amendment.

Idaho practice today. To vote in person, Idaho law requires personal identification, and Idaho Code section 34-1113 lists the accepted forms. A registered voter who has none of them may instead sign a Personal Identification Affidavit.¹⁶¹³ The affidavit route is the sort of no-cost alternative that makes a photo ID rule easier to defend against a claim that the rule works as a charge for voting. This lesson could not confirm whether the cost of obtaining the underlying documents has been litigated in Idaho.

Felony convictions and money. Idaho Const. art. VI, sec. 3 bars from voting a person convicted of a felony "who has not been restored to the rights of citizenship," or who is confined in prison. Idaho Code section 18-310(2) restores full rights of citizenship on "final discharge," defined as "satisfactory completion of imprisonment, probation and parole as the case may be."¹⁴¹⁷ The statute does not mention fines, fees or restitution by name, but a court can make payment a condition of probation, so unpaid money may in practice affect whether discharge is "satisfactory." This lesson did not find an Idaho appellate decision addressing the question under the Twenty-fourth Amendment, so the application of Jones to Idaho is open.¹¹

Where This Shows Up for Officials, Reporters and Citizens

The county clerk and the replacement card

Clerk Helen Marsh runs elections in a small invented county. A precinct worker tells a voter that the registration card she misplaced must be replaced for $3 before she can vote. Marsh can tell the worker the rule is wrong. A fee cannot be a condition of voting, and a $3 charge is the same kind of charge as $1.50 was in 1966. If the county has a fee for a duplicate card, the card must be optional, and a voter without it must be able to vote by showing one of the accepted forms of ID or signing the affidavit.²¹³

The legislative staffer drafting a restoration bill

A staffer for an invented state senator is drafting a bill that ties voting rights after a felony to payment of court costs. The Eleventh Circuit's Jones decision says fees and costs in a sentence are not taxes, so the Twenty-fourth Amendment will not stop such a bill in that circuit. Other constitutional questions, including equal protection claims, were argued separately in Jones and the staffer should read those parts of the opinion as well. The staffer should also check whether the bill would ask people to pay money they cannot pay and whether the State offers a path for people unable to pay.¹⁰

The reporter checking a "poll tax" claim

An advocacy group tells a reporter that a county's new $10 charge for early voting is a "modern poll tax." The reporter's first questions are mechanical. Is the charge a condition of casting a ballot, or an optional service? Is the election federal, state or local? If the answer is that voters cannot vote without paying, Harper and Harman apply and the story is a real constitutional problem. If the charge pays for an optional convenience, the claim is more political than legal. The reporter should quote the text of the amendment and the line in Harper about the interest of the State being limited to "the power to fix qualifications."²

The citizen who is not sure of the rules

A voter in an invented Idaho county asks whether a past felony still blocks her vote. Under Idaho Code section 18-310(2) rights are restored upon final discharge, meaning completion of imprisonment, probation and parole.¹⁷ The county clerk's office and the Secretary of State's office are where to confirm what applies to a particular sentence, since this lesson could not confirm how unpaid fines or restitution are treated.

Related Modules

• Module 2, Article I: Congress: the Elections Clause and the rule that voter qualifications follow the State's lower house.
• Module 5, Federalism and the States: why voting qualifications began as a State matter.
• Module 11, Voting, Taxes and the Later Amendments: the overview of this and nearby amendments.
• Module 10, The Civil War Amendments: the Fourteenth and Fifteenth Amendments that supply the language and the equal protection argument.
• Module 28, The Fourteenth Amendment: the Equal Protection Clause behind Harper.
• Module 29, The Fifteenth Amendment: the "denied or abridged" voting language and the Voting Rights Act.
• Module 32, The Nineteenth Amendment: the other amendment that bars denial of the vote on a single ground.
• Module 36, The Twenty-Third Amendment: electoral votes for the District of Columbia, passed the year before.
• Module 39, The Twenty-Sixth Amendment: the age amendment, Oregon v. Mitchell and the same "denied or abridged" text.
• Module 40, The Twenty-Seventh Amendment: another amendment with no ratification deadline.

Sources & Further Reading

Primary Sources

• National Archives, The Constitution: Amendments 11-27
• National Archives, The Constitution of the United States: A Transcription
• House Manual (116th Congress), Amendment XXIV and ratification notes
• Harper v. Virginia State Board of Elections, 383 U.S. 663 (1966)
• Harman v. Forssenius, 380 U.S. 528 (1965)
• Crawford v. Marion County Election Board, 553 U.S. 181 (2008)
• Jones v. Governor of Florida, No. 20-12003 (11th Cir. Sept. 11, 2020) (en banc), corrected opinion
• Voteview, House Vote 193, August 27, 1962 (S.J. Res. 29)

Idaho Law and Records

• Idaho Const. art. VI, sec. 2
• Idaho Const. art. VI, sec. 3
• Idaho Const. art. VI, sec. 4
• Idaho Code sec. 34-402
• Idaho Code sec. 34-1113
• Idaho Code sec. 18-310
• Idaho Secretary of State, VoteIdaho.gov, Frequently Asked Questions

Secondary Sources and Further Reading

• Constitution Annotated, Amendment XXIV: Overview
• Constitution Annotated, Amendment XXIV: Doctrine
• HISTORY, "Here's Why You Don't Need to Pay a Tax to Vote" (secondary source)

Footnotes

1. National Archives, The Constitution of the United States: A Transcription, https://www.archives.gov/founding-docs/constitution-transcript. Article I, section 2, clause 1: electors for the House "shall have the Qualifications requisite for Electors of the most numerous Branch of the State Legislature."
2. Harper v. Virginia State Board of Elections, 383 U.S. 663 (1966), decided March 24, 1966, opinion of Justice Douglas and dissents of Justice Black and of Justice Harlan (joined by Justice Stewart), https://www.law.cornell.edu/supremecourt/text/383/663. All quotations from the majority and dissents in this lesson are from this text.
3. Constitution Annotated, Amendment XXIV, Overview of Twenty-Fourth Amendment, Abolition of Poll Tax, https://www.law.cornell.edu/constitution-conan/amendment-24/overview-of-twenty-fourth-amendment-abolition-of-poll-tax. Source for the effort begun in Congress in 1939, the eleven Southern States that adopted poll tax qualifications after Reconstruction, the five that still had them at ratification, H.R. Rep. No. 1821 (87th Cong., 2d Sess.), and the earlier cases Breedlove, Saunders v. Wilkins and Butler v. Thompson.
4. Zachary Clary, "Here's Why You Don't Need to Pay a Tax to Vote," HISTORY, published January 5, 2024, last updated May 27, 2025, https://www.history.com/articles/poll-tax-24th-amendment. Source for Senator Spessard Holland's procedure, the March 14, 1962 opening of debate, the filibuster, the 77 to 16 Senate vote, the five States that kept the tax, and the historian Keith Finley's remark about literacy tests. This is a secondary source; its Senate vote count matches the figure in the Wikipedia article on the amendment, which this lesson did not rely on.
5. National Archives, The Constitution: Amendments 11-27, https://www.archives.gov/founding-docs/amendments-11-27. Gives the full text of the Twenty-fourth Amendment, with "Passed by Congress August 27, 1962. Ratified January 23, 1964."
6. Constitution Annotated, Amendment XXIV, Doctrine on Abolition of Poll Tax, https://www.law.cornell.edu/constitution-conan/amendment-24/doctrine-on-abolition-of-poll-tax. Source for the Voting Rights Act of 1965, section 10, the Attorney General suits in United States v. Texas and United States v. Alabama, the holding in Harper, and the unanimous holding in Harman v. Forssenius.
7. Voteview (UCLA), 87th Congress, House, Vote 193, August 27, 1962, https://voteview.com/rollcall/RH0870193. Records the result as 295 to 86 on S.J. Res. 29, "Constitutional Amendment to Ban the Use of Poll Tax as a Requirement for Voting in Federal Elections."
8. Constitution, Jefferson's Manual, and the Rules of the House of Representatives, 116th Congress, Amendment XXIV, note 15, https://www.govinfo.gov/content/pkg/HMAN-116/html/HMAN-116-pg118.htm. States that the 87th Congress proposed the amendment to the States on August 28, 1962, that the Administrator of General Services declared it ratified by 38 States in a proclamation dated February 4, 1964, and lists each ratification date: Illinois, November 14, 1962, first; Idaho, March 8, 1963; Maine, January 16, 1964; South Dakota, January 23, 1964, completing ratification. It records Mississippi's rejection on December 20, 1962, and later ratifications by Virginia (February 25, 1977), North Carolina (May 3, 1989), Alabama (September 26, 2002) and Texas (May 22, 2009).
9. Harman v. Forssenius, 380 U.S. 528 (1965), argued March 1 and 2, decided April 27, 1965, opinion of Chief Justice Warren, https://www.law.cornell.edu/supremecourt/text/380/528. The opinion describes Virginia Code section 24-17.2 and quotes Lane v. Wilson and Smith v. Allwright.
10. Jones v. Governor of Florida, 975 F.3d 1016 (11th Cir. 2020) (en banc), No. 20-12003, decided September 11, 2020, Part III-B, https://www.brennancenter.org/sites/default/files/2020-09/2020-09-11%20Corrected%20Opinion.pdf (copy of the corrected opinion hosted by the Brennan Center). The court held that fees and costs imposed in a criminal sentence are not taxes under the Twenty-fourth Amendment, and that fines and restitution are not taxes under any fair reading.
11. This lesson searched for an Idaho appellate decision applying the Twenty-fourth Amendment and found none. That is a statement about this lesson's search, not a finding that none exists.
12. Crawford v. Marion County Election Board, 553 U.S. 181 (2008) (opinion of Stevens, J.), https://www.law.cornell.edu/supct/html/07-21.ZO.html. Describes Harper as holding that Virginia could not condition the right to vote in a state election on payment of a $1.50 poll tax and explains how Anderson v. Celebrezze's balancing approach relates to it.
13. Idaho Secretary of State, VoteIdaho.gov, Frequently Asked Questions, https://voteidaho.gov/frequently-asked-questions/, page opened October 18, 2026: "A registered voter may sign a Personal Identification Affidavit instead of presenting photo identification."
14. Idaho Constitution, art. VI, sec. 2 (qualifications of electors), https://legislature.idaho.gov/statutesrules/idconst/ArtVI/Sect2/; sec. 3 (disqualification of certain persons), https://legislature.idaho.gov/statutesrules/idconst/ArtVI/Sect3/; sec. 4 (legislature may prescribe additional qualifications), https://legislature.idaho.gov/statutesrules/idconst/ArtVI/Sect4/.
15. Idaho Code section 34-402 (qualifications of electors), https://legislature.idaho.gov/statutesrules/idstat/Title34/T34CH4/SECT34-402/. Citizenship, eighteen years of age, thirty days of residence in the State and county, and timely registration. The history note shows the section added in 1970 and amended in 1971, 1972, 1973 and 1982.
16. Idaho Code section 34-1113 (identification at the polls), https://legislature.idaho.gov/statutesrules/idstat/Title34/T34CH11/SECT34-1113/. Lists the accepted forms of personal identification; amended 2023, ch. 27.
17. Idaho Code section 18-310 (imprisonment, effect on civil rights), https://legislature.idaho.gov/statutesrules/idstat/Title18/T18CH3/SECT18-310/. Subsection (2): upon final discharge a person convicted of an Idaho felony "shall be restored the full rights of citizenship," with "final discharge" meaning "satisfactory completion of imprisonment, probation and parole as the case may be."