In the case of Harman et al. v. Forssenius et al., 1964, the Supreme Court ruled that a Virginia law requiring federal voters to re-register and pay a poll tax or file a certificate of residency was unconstitutional under the 24th Amendment, which prohibits any poll tax in elections for federal officials. The state argued that it had not violated this amendment as it offered an alternative to paying the poll tax - filing a certificate of residency six months prior to election day. However, the court found this alternative burdensome and held that it effectively continued disenfranchisement based on wealth status by imposing unnecessary obstacles for potential voters who could not afford or did not wish to pay such taxes.

In the dissenting opinion for Harman et al. v. Forssenius et al., Justice John Marshall Harlan II argued that the majority's decision was an overreach of judicial power, infringing upon states' rights to regulate their own voting procedures. He contended that Virginia's poll tax did not violate the 24th Amendment as it offered a reasonable alternative in form of a certificate of residency for those unable or unwilling to pay the tax. According to him, this option ensured no citizen was denied their right to vote due to inability to pay any kind of tax and thus complied with federal law. Furthermore, he believed that by striking down Virginia’s poll tax system entirely rather than just its discriminatory aspects, the court had unnecessarily interfered with state sovereignty and exceeded its constitutional authority.