Breedlove v. Suttles

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Breedlove v. Suttles (1937) – Easy Summary

Background
Georgia charged a poll tax of $1 per year to vote in state elections. The law exempted people under 21 or over 60, and it allowed women who did not register to vote to be exempt from paying the tax. Nolan Breedlove, a 28-year-old white man, refused to pay the tax and was barred from registering to vote. He challenged the law under the Fourteenth Amendment (equal protection and privileges and immunities) and the Nineteenth Amendment.

The Case
Breedlove sued in Fulton County, Georgia, arguing that the poll tax violated his constitutional rights. T. Earl Suttles, the county tax collector, was named as the defendant in his official capacity.

Opinion of the Court
The Supreme Court, in a unanimous decision written by Justice Pierce Butler, upheld Georgia’s poll tax law. The Court said the tax was constitutional and that sex-based exemptions were permissible because women carry particular burdens in bearing and rearing children. It also treated the upper age limit for the tax as similar to exemptions routinely given for military or jury service. On the Nineteenth Amendment claim, the Court rejected the idea that the tax denied or abridged men’s right to vote on account of sex.

Subsequent Developments
Georgia abolished its poll tax in 1945. Breedlove’s ruling remained controlling law until 1966, when the Supreme Court reversed it in Harper v. Virginia State Board of Elections, ruling that poll taxes violate equal protection in state elections. The Twenty-Fourth Amendment, ratified in 1964, prohibited poll taxes as a prerequisite for federal elections. Justice Hugo Black, who participated in Breedlove, also participated in Harper but dissented in Harper, arguing against striking down the poll tax.

Significance
Breedlove v. Suttles reflected a period when poll taxes could be upheld as constitutional, including allowances for sex and age exemptions. It was overturned in the Civil Rights era as the Court and the country moved toward guaranteeing voting rights free from such preconditions.