Court membership had changed, and the justices examined the issue from a different point of view. Dissents Joined by Justice Potter Stewart, Justice John Marshall Harlan II dissented, arguing that the Court had allowed some forms of discriminatory voting qualifications without violating the equal protection clause, e.g., Lassiter v. Northampton County Board of Elections (literacy test), Breedlove v. Suttles (poll tax on men), as long as it was rational. In this case, Virginia's poll tax could be deemed rational because of the state's desire to collect revenue and the belief that people who pay to vote might have more interest in the state's policies. Justice Hugo Black filed a separate dissent. Black based his dissent mainly on stare decisis basis. As a textualist, he also criticized the majority for expanding the meaning of the Fourteenth Amendment by using what he called the old "natural law due process formula". He emphasized that new meanings can be added to the Constitution only through amendments. Justice Black tended to have a complicated approach to the fourteenth amendment, as he had vehemently defended and joined the court's decision in Brown v. Board of Education (1954), which ordered the desegregation of public schools in the nation. See also List of United States Supreme Court cases, volume 383 Joseph A. Jordan Jr. References External links The Voting Rights Act of 1965, USDOJ.gov John C. Bonifaz, "Not the Rich, More Than the Poor: Poverty, Race, and Campaign Finance Reform" United States Supreme Court decisions that overrule a prior Supreme Court decision History of voting rights in the United States United States equal protection case law United States Twenty-fourth Amendment case law United States Supreme Court cases 1966 in United States case law Legal history of Virginia Civil rights movement case law African-American history of Virginia Virginia elections United States Supreme Court cases of the Warren Court 1966 in Virginia United States racial discrimination case law