“Proposition 200’s polling place provision is not a poll tax under Harman. Requiring voters to show identification at the polls does not constitute a tax. Nor does the identification requirement place a material burden on a voter “solely because of his refusal to waive [his] constitutional immunity” to a poll tax, id.; rather, under Proposition 200, all voters are required to present identification at the polls. Because Arizona’s
system does not, as a matter of law, qualify as a poll tax, we affirm the district court’s conclusion that Proposition 200’s polling place provision does not violate the Twentyfourth Amendment.” Full opinion here, quote from page 43-44.
When you adopt a position more extreme than the 9th Circuit, you are really out on the fringes.