Pitts v. Black was a 1984 legal case in the U.S. District Court S.D.N.Y establishing eligible American voters residing in non-conventional accommodations cannot be refused to register to vote.

[6] The main claim of the defendant stated that homeless people do not comply with the term residence as defined under the election law: "that place where a person maintains a fixed, permanent and principal home and to which he, wherever temporarily located, always intends to return.

"[1] The defendant also argued that voter's compliance to the term residence safeguards three compelling state interest: 1) proving the link between the voter and the electoral district 2) preventing election fraud via mail check 3) preserving administrative feasibility as it is not practical to notify the homeless via mail about polling station location.

[1] Based on its findings, the court ruled that there are other ways to preserve the three compelling state interests (listed above) rather than disenfranchising a whole class of people from voting.

The court concluded a specific location where the homeless returns regularly and a place designated to receive mail should satisfy.

[7] On 9 October 1984, the court ruled that, by refusing the homeless to register to vote, the New York City Board of Elections was in breach of the equal protection clause under the Fourteen Amendment.

[3] Even to today the National Coalition for the Homeless encourages eligible American voters in non-traditional residence to register.