A district court holds that a residency requirement established by the Virginia legislature as an alternative to payment of a poll tax in federal elections is an additional qualification to voting, which violates the Seventeenth Amendment and Article I, section 2 of the Constitution. In Harman v. Forssenius, the Supreme Court agrees but bases its ruling of unconstitutionality on the Twenty-fourth Amendment (which outlawed poll taxes) rather than the Seventeenth Amendment.