laws can suppress electoral participation among eligible voters by discouraging voting among family and community members of disenfranchised persons. Future electoral participation by the children of disenfranchised parents may be impacted as well. (15) The United States is one of the only Western democracies that permits the permanent denial of voting rights for individuals with felony convictions. (16) The Eighth Amendment’s prohibition on cruel and unusual punishments guarantees individuals the right not to be subjected to excessive sanctions . (Roper v. Simmons, 543 U.S. 551, 560 (2005)). That right stems from the basic precept of justice that punishment for crime should be graduated and proportioned to [the] offense . Id. (quoting Weems v. United States, 217 U.S. 349, 367 (1910)). As the Supreme Court has long recognized, [t]he concept of proportionality is central to the Eighth Amendment . (Graham v. Florida, 560 U.S. 48, 59 (2010)). Many State disenfranchisement laws are grossly disproportional to the offenses that lead to disenfranchisement and thus violate the bar on cruel and unusual punishments. For example, a number of States mandate lifetime disenfranchisement for a single felony conviction or just two felony convictions, even where the convictions were for non-violent offenses. In numerous other States, disenfranchisement can last years or even decades while individuals remain on probation or parole, often only because a person cannot pay their legal financial obligations. These kinds of extreme voting bans run afoul of the Eighth Amendment. (17) The Twenty-Fourth Amendment provides that the right to vote shall not be denied or abridged by the United States or any State by reason of failure to pay any poll tax or other tax . Section 2 of the Twenty-Fourth Amendment gives Congress the power to enforce this article by appropriate legislation. Court fines and fees that individuals must pay to have their voting rights restored constitute an other tax for purposes of the Twenty-Fourth Amendment. At