of the laws. The poll tax, along with literacy tests and extra-legal intimidation, such as by the Ku Klux Klan, achieved the desired effect of disenfranchising African Americans. Generally, In the United States, the term "poll tax" is used to mean a tax that must be paid in order to vote, rather than a capitation tax simply. For example, a bill that passed the Florida House of Representatives in April 2019 has been compared to a poll tax because it requires former felons to pay all "financial obligations" related to their sentence, including court fines, fees, and judgments, before their voting rights will be restored as required by a referendum that passed with 64% of the vote in 2018. The Twenty-fourth Amendment, ratified in 1964, prohibits both Congress and the states from conditioning the right to vote on payment of a poll tax or any other type of tax. Capitation and federal taxation The ninth section of Article One of the Constitution places several limits on Congress's powers. Among them: "No capitation, or other direct, tax shall be laid, unless in proportion to the census or enumeration herein before directed to be taken". Capitation here means a tax of a uniform, fixed amount per taxpayer. Direct tax means a tax levied directly by the United States federal government on taxpayers, as opposed to a tax on events or transactions. The United States government levied direct taxes from time to time during the 18th and early 19th centuries. It levied direct taxes on the owners of houses, land, slaves and estates in the late 1790s but cancelled the taxes in 1802. An income tax is neither a poll tax nor a capitation, as the amount of tax will vary from person to person, depending on each person's income. Until a United States Supreme Court decision in 1895, all income taxes were deemed to be excises (i.e., indirect taxes). The Revenue Act of 1861 established the first income tax in the United States, to pay for the cost of the American Civil War. This income tax was abolished after the war, in 1872. Another income tax statute in 1894 was overturned in Pollock v. Farmers' Loan & Trust Co. in 1895, where the Supreme Court held that income taxes on income from property, such as rent income, interest income, and dividend income (however excepting income taxes on income from "occupations and labor"