In the 1860s, suffragette Sarah E. Wall of Worcester, Massachusetts invoked the principle of “no taxation without representation”, initiating an anti-tax protest in which she encouraged women not to pay taxes until they were granted the right to vote.

Soon after she began this movement, the Worcester city tax collector sued Wall for refusing to pay taxes, and the case reached the Massachusetts Supreme Court in 1863. In “Wheeler v. Wall,” the court ruled against Wall and held that despite not having the right to vote, women are still obligated to meet their tax burden. Even still, Wall refused to cooperate with the collector, and as a result, officers seized and sold her property in order to raise the money necessary to meet her tax obligation.

After several years, Wall’s inexorability eventually prevailed, as the collector began to ignore Wall and allow her to abstain from paying taxes.^[88] In 1884, Susan B. Anthony cited Wall’s audacity and willingness to stand up for women’s suffrage, stating, “for the last twenty-five years, [she] has resisted the tax gatherer when he came around. I want you to look at her. She looks very harmless, but she will not pay a dollar of tax.

She says when the Commonwealth of Massachusetts will give her the right of representation she will pay her taxes.”^[89]

The phrase is also used by other groups in America who pay various types of taxes (sales, income, property) but lack the ability to vote, such as felons (who are, in many states, barred from voting), people who work in one state and live in another (thus having to pay income tax to a state they don’t live in), or people under 18.^[90]

To become citizens of the United States, immigrants most often must be permanent residents for a period of time (usually 5 years).^[91]

Permanent residents must pay taxes on their worldwide income and, in most cases, cannot vote. However, throughout the 19th century, many states did allow immigrants to vote after they had declared their intention to become citizens. This was primarily because these new states were populated in large part by immigrants who had not yet attained citizenship.

Throughout U.S. history, non-citizens have been allowed to vote in 40 U.S. states and territories.^[92] As of 2005, non-citizens are allowed to vote in seven jurisdictions in the United States: Chicago and six towns in Montgomery County, Maryland.^[93]

In 2009, the phrase “taxation without representation” was also used in the Tea Party protests, where protesters were upset over increased government spending and taxes, and specifically regarding a growing concern amongst the group that the U.S. government is increasingly relying upon a form of taxation without representation through increased regulatory levies and fees which are allegedly passed via unelected government employees who have no direct responsibility to voters and cannot be held accountable by the public through elections.^[94]

A modified version of the phrase, “no tuition without representation”, is sometimes used in disputes over governance in higher education in the United States to emphasize student’s rights to a voice in institutional decisions. The term first emerged in a 1977 dispute at Union County College in New Jersey.^[95] It has been used more recently in disputes at Dartmouth College,^[96]UC Berkeley School of Law,^[97] and elsewhere.