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In U.S. practice, a poll tax was used as a de facto or implicit pre-condition of the exercise of the ability to vote. This tax emerged in some states of the United States in the late 19th century as part of the Jim Crow laws. After the ability to vote was extended to all races by the enactment of the Fifteenth Amendment, many Southern states enacted poll tax laws as a means of restricting eligible voters; such laws often included a grandfather clause, which allowed any adult male whose father or grandfather had voted in a specific year prior to the abolition of slavery to vote without paying the tax. These laws, along with unfairly implemented literacy tests and extra-legal intimidation, achieved the desired effect of disfranchising African-American and Native American voters, as well as poor whites.
Although largely associated with states of the former Confederacy, poll taxes were also in place in other states. For instance, California had a poll tax until 1914 when it was abolished through a popular referendum.
Initially, the United States Supreme Court, in the case of Breedlove v. Suttles, 302 U.S. 277 (1937), found the poll tax to be constitutional. The 24th Amendment, ratified in 1964, reflecting a political compromise, abolished the use of the poll tax (or any other tax) as a pre-condition for voting in federal elections, but made no mention of poll taxes in state elections.
In the 1966 case of Harper v. Virginia Board of Elections, the Supreme Court overruled its decision in Breedlove v. Suttles, and extended the prohibition of poll taxes to state elections. It declared that the imposition of a poll tax in state elections violated the Equal Protection Clause of the 14th Amendment to the United States Constitution.
The Harper ruling was one of several that rely on the Equal Protection clause of the 14th Amendment rather than the more direct provision of the 15th Amendment. In a two-month period in the spring of 1966, Federal courts declared unconstitutional poll tax laws in the last four states to have them, starting with Texas on 9 February. Decisions followed for Alabama (3 March) and Virginia (25 March). Mississippi's $2.00 poll tax (equal to $14.54 in 2013) was the last to fall, declared unconstitutional on 8 April 1966, by a federal panel in Jackson, Mississippi. Virginia attempted to partially abolish its poll tax by requiring a residence certification, but the Supreme Court did not accept this.