In the case of Hadnott et al. v. Amos, Secretary of State of Alabama, et al., 1968, African American voters in Lowndes County, Alabama challenged a state statute that required candidates for county office to pay a filing fee equal to 2% of the annual salary for the position sought. The plaintiffs argued that this law was discriminatory and violated their rights under the Fourteenth and Fifteenth Amendments because it effectively barred poor black citizens from running for office. They also claimed that white officials had manipulated election procedures to maintain control over local government despite a majority-black population. The Supreme Court ruled in favor of Hadnott and his co-plaintiffs by striking down the filing fee requirement as unconstitutional due to its discriminatory impact on minority candidates who could not afford such fees. This decision underscored how economic barriers can serve as tools for racial discrimination within electoral processes.

In the dissenting opinion for Hadnott et al. v. Amos, Secretary of State of Alabama, et al., Justice Harlan argued that the majority's decision to invalidate a state law requiring candidates to pay a filing fee was an overreach of federal power and violated principles of federalism. He contended that there was no evidence presented in this case showing that the filing fee requirement had been used as a tool for racial discrimination or voter suppression. Therefore, he believed it should be upheld under states' rights to regulate their own elections within constitutional limits. Furthermore, Justice Harlan expressed concern about potential negative implications on future election laws if such requirements were deemed unconstitutional without clear proof they were being misused.