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Orleans v. Platt was a United States Supreme Court case that addressed the issue of whether a state legislature could pass a law that would require a person to pay a fee in order to vote in a state election. The case was brought by a group of citizens from Orleans Parish, Louisiana, who argued that the state legislature had passed a law that required them to pay a fee in order to vote in a state election. The Supreme Court held that the law was unconstitutional, as it violated the Equal Protection Clause of the Fourteenth Amendment. The Court reasoned that the law was a form of taxation, and that it was not a reasonable means of regulating the voting process. Furthermore, the Court held that the law was not necessary to prevent fraud or to ensure the integrity of the election process. The Court concluded that the law was an unconstitutional infringement on the right to vote. As a result, the Court struck down the law and declared it void.
In the case of Orleans v. Platt, the Supreme Court was asked to determine whether a state legislature had authority to pass a law that would allow for an individual's right to vote in local elections without having been previously registered as a voter. The majority opinion held that such legislation was unconstitutional and violated Article I, Section 2 of the U.S Constitution which states that "the qualifications requisite for electors in each State shall be prescribed by its Legislature". Justice Field dissented from this ruling arguing that while it is true Congress has exclusive power over federal elections, they do not have any control over state or local elections and thus cannot interfere with how those are conducted. He further argued that since voting rights are fundamental civil liberties protected under both Federal and State Constitutions, allowing individuals who meet certain requirements set forth by their respective legislatures should be allowed to participate in these types of elections regardless if they were previously registered or not.