Abbott v. Perez

Last updated

Abbott v. Perez
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued April 24, 2018
Decided June 25, 2018
Full case nameGreg Abbott, Governor of Texas, et al. v. Shannon Perez, et al.
Docket nos. 17-586
17-626
Citations585 U.S. ___ ( more )
138 S. Ct. 2305; 201 L. Ed. 2d 714; 2018 U.S. LEXIS 3846; 2018 WL 3096311
Case history
PriorPerez v. Abbott, 267 F. Supp. 3d 750 (W.D. Tex. 2017); 274 F. Supp. 3d 624 (W.D. Tex. 2017)
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Samuel Alito  · Sonia Sotomayor
Elena Kagan  · Neil Gorsuch
Case opinions
MajorityAlito, joined by Roberts, Kennedy, Thomas, Gorsuch
ConcurrenceThomas, joined by Gorsuch
DissentSotomayor, joined by Ginsburg, Breyer, Kagan

Abbott v. Perez, 585 U.S. ___ (2018), was a United States Supreme Court case dealing with the redistricting of the state of Texas following the 2010 census.

Contents

Background

As a result of the 2010 United States census, the state of Texas was found to have gained more than four million new residents, many of them of Latino or African-American heritage. This granted Texas four additional seats in the United States House of Representatives, requiring the state to redraw both its congressional and legislative districts to incorporate these four new seats. At this time, the Texas state government was controlled by the Republican Party. Initial redistricting maps were completed by the state legislature by 2011, and sent to the United States District Court for the District of Columbia for preclearance as required by Section 5 of the Voting Rights Act of 1965 (VRA). While the District Court reviewed the maps, some Texas citizens believed the redistricting diluted minority votes and used unconstitutional racial gerrymandering to define the new districts, violating both Section 2 of the VRA, and filed a separate suit in the United States District Court for the Western District of Texas. The Texas federal district court heard arguments in this case, but held off ruling until the preclearance was completed. However, with the 2012 elections nearing, the D.C. federal district court recognized it would not be able to complete the preclearance in time. The Texas federal district court, using proposals from parties in the current Section 2 case, developed the three interim district plans for the state's congressional and legislative districts by November 2011. [1]

The state, defending its maps, issued an emergency request to the United States Supreme Court to reject the District Court maps. The Supreme Court agreed to the emergency request, and on January 20, 2012, vacated the maps developed by the Texas federal district court and instructed it to draw up new maps. [2] [3] The Texas federal district court used the state-derived maps as a starting point and issued their new maps by February 2012. [4] [5] Separately, the D.C. federal district court continued the evaluation of the redistricting maps, and ruled that all three redistricting maps provided by the state for preclearance did not meet the requirements for Section 5 of the VRA by August 2012. [6] The judges determined that the state had not been able to prove that the redistricting plan was developed without intentional discrimination. [7] Due to timing with the 2012 elections to be held in November, Texas continued to use the Texas federal district court-derived maps.

During these events, the Supreme Court ruled in Shelby County v. Holder [8] that the means of which states were determined to have preclearance of voter-related laws was unconstitutional, eliminating the need for Texas to seek preclearance of their maps. [9] The state, with only minor changes, adopted all three maps from the Texas federal district court as the permanent maps in June 2013. [10]

The original suit in the Texas federal district court continued, with petitioners seeking to also amend the 2013 redistricting maps as part of their complaints, as to prevent these maps to be used in the next set of elections. This case became protracted in the District Court, but ultimately the court issued its ruling in August 2017. It ruled that the 2011 redistricting map violated either the VRA or the Constitution or a combination of both, and because the state used the maps proposed by Texas federal district court based on the original state maps following the U.S. Supreme Court ruling as the basis for the 2013 redistricting, that these were also similarly flawed. [11] [12] The court ordered the Texas governor to call a special meeting of legislators to redraw the maps in a timely manner, but the state instead turned to the U.S. Supreme Court to appeal the opinion, as well as to freeze the Texas federal district court's order to redraw the maps due to nearness of the 2018 elections. In a 5–4 decision split between the conservative and liberal justices, the U.S. Supreme Court agreed in September 2017 to freeze the redistricting order, [13] and hear the case in January 2018. [14]

U.S. Supreme Court

The case presented at the U.S. Supreme Court combines two separate rulings issued by the Texas federal district court on the redistricting maps. The state in their petition asked on several issues, including whether the 2013 maps, adopted from those presented by the Texas District Court, could be considered unconstitutional, whether the Texas federal district court had ruled appropriately in challenging specific district lines identified in the 2013 maps, and whether the Texas federal district court had authority to demand the rapid redistricting session. The Court itself further considered if they had jurisdiction on the case, given that their action to freeze the Texas federal district court's ruling could have been seen as premature. Oral arguments were heard on April 24, 2018, with observers stating that the judges appeared to be split along conservative and liberal lines. [15] Allison Riggs argued the case for the plaintiffs (Perez, et al.). [16]

The decision was issued on June 25, 2018. [17]

Opinion of the Court

In a 5–4 decision written by Justice Samuel Alito, the Court upheld the current redistricting maps as valid districts, outside of one district, Texas House District 90 near Fort Worth, which the court found was an "impermissible racial gerrymander", remanding the case to lower courts to correct the redistricting to eliminate the racial gerrymandering. [18] [19]

The court majority stated that state legislatures are entitled to a presumption of legislative good faith, especially in districting cases. [20] [21] [22] "Whenever a challenger claims that a state law was enacted with discriminatory intent," Justice Samuel Alito stated in the opinion of the Court, "the burden of proof lies with the challenger, not the State." [23] Although there was evidence of discrimination by the state in the past, this past discrimination was not sufficient to undermine the good faith presumption. [20] "This means that the plaintiffs challenging a redistricting plan still have to show that the legislature intended to discriminate when it enacted the current plan." [22]

Concurrence and Dissent

Justice Clarence Thomas, joined by Neil Gorsuch, filed a concurrence asserting that redistricting is not covered by the Voting Rights Act. [17] [24] On behalf of the court's four liberals, Justice Sonia Sotomayor criticized the conservative majority. The majority's "disregard for both precedent and fact comes at serious costs to our democracy," she wrote in 46-page dissent. "It means that after years of litigation and undeniable proof of intentional discrimination, minority voters in Texas ... will continue to be underrepresented in the political process." [17] Justice Sotomayor also accused the court of running interference for racists by "blind[ing] itself to the overwhelming factual record" to let Texas use maps that, "in design and effect, burden the rights of minority voters." Justice Alito, Justice Sotomayor wrote, is "just flat wrong," relying on "a selective reading" of the facts to ignore clear evidence of "racial discrimination." [24]

Impact and criticism

The Voting Rights Acts of 1965 contains a section known as Section 2. [25] [26] : 3–4  Section 2 encompasses two separate parts which are designed to protect against voting discrimination. Election laws enacted with racially discriminatory intent are prohibited by the first part. [23] [27] The second part is a prohibition of any voting procedure that "results in a denial or abridgement of the right of any citizen of the United States to vote on account of race or color." [28] [25] These two prongs of Section 2 are known as the "intent" test and the "results" test. [23] The Supreme Court's holding in City of Mobile v. Bolden (1980) made it nearly impossible to win Section 2 suits, because plaintiffs must prove that the lawmakers who passed voting-related laws acted with "racially discriminatory motivation." [29] [25] Congress overrode the Mobile decision with the aforementioned second Section 2 prohibition. This made suits easier for plaintiffs, because they no longer needed to prove racist intent. Plaintiffs must only show that the voting-related law had a disparate negative effect on voters of color. [30] : 15–16, 21, 24–25 and 37  [29] [31] [25]

Vox journalist Ian Millhiser stated in several articles [21] [23] [25] that the Abbott decision, under which courts must apply a strong presumption that lawmakers did not act with racist intent, [23] makes Section 2 suits more difficult because "lawmakers enjoy such a strong presumption of racial innocence that it is now extremely difficult to prove that those lawmakers acted with racist intent — so difficult that it may be impossible except in the most egregious cases." [25] He compared an argument made by Justice Alito in the Abbott decision with resistance by Southern States to the 1954 Supreme Court ruling in Brown v. Board of Education : "Alito's argument, in other words, is that the 2013 maps weren't enacted to preserve a racial gerrymander; they were enacted to shut down litigation challenging a racial gerrymander. And this distinction is sufficient to cleanse the state legislature of any allegation of racism. It's as if the school districts on the losing end of Brown v Board of Education (1954) had passed a new law recreating the same racially segregated schools that were challenged in the Brown litigation, but claimed that these segregated schools should be upheld because the new law had a legitimate purpose — to bring the litigation challenging public school segregation to an end as expeditiously as possible."

Journalist Vann R. Newkirk II asserted in July 2018 that the Roberts Court with its Shelby County v. Holder decision along with the 2018 Supreme Court decisions in Husted v. Randolph Institute [32] [33] and Abbott v. Perez [17] has "set the stage for a new era of white hegemony", because these cases "furthered Roberts's mandate to distance the federal judiciary from Thurgood Marshall's vision of those bodies as active watchdogs for the Fourteenth and arbiters for America's racial injustices." [34] With the three cases together "the Court has established that not only are the legacies of Jim Crow no longer a valid justification for proactive restrictions on states, but the Court doesn't necessarily have a role in advancing the spirit of the franchise. Furthermore, with Alito's gerrymandering decision, the Court holds that past discrimination by states—even at its boldest and most naked—is not really a consideration in assessments of current policies. This part is crucial, because in an era where crafty state politicians have moved toward race-neutral language that clearly still seeks to disenfranchise people of color, a certain default suspicion by federal courts and the Department of Justice based on those state politicians' histories has been the main protective force for the minorities' voting rights. That suspicion is gone now, as are all vestiges of Marshall's intended vigilance." [34]

See also

Related Research Articles

<span class="mw-page-title-main">Voting Rights Act of 1965</span> US federal legislation that prohibits racial discrimination in voting

The Voting Rights Act of 1965 is a landmark piece of federal legislation in the United States that prohibits racial discrimination in voting. It was signed into law by President Lyndon B. Johnson during the height of the civil rights movement on August 6, 1965, and Congress later amended the Act five times to expand its protections. Designed to enforce the voting rights protected by the Fourteenth and Fifteenth Amendments to the United States Constitution, the Act sought to secure the right to vote for racial minorities throughout the country, especially in the South. According to the U.S. Department of Justice, the Act is considered to be the most effective piece of federal civil rights legislation ever enacted in the country. It is also "one of the most far-reaching pieces of civil rights legislation in U.S. history."

<span class="mw-page-title-main">North Carolina's congressional districts</span> U.S. House districts in the state of North Carolina

North Carolina is currently divided into 14 congressional districts, each represented by a member of the United States House of Representatives. After the 2000 census, the number of North Carolina's seats was increased from 12 to 13 due to the state's increase in population. In the 2022 elections, per the 2020 United States census, North Carolina gained one new congressional seat for a total of 14.

<span class="mw-page-title-main">2003 Texas redistricting</span> Controversial redistricting of Texass districts for the U.S. House of Representatives

The 2003 Texas redistricting was a controversial intercensus state plan that defined new congressional districts. In the 2004 elections, this redistricting supported the Republicans taking a majority of Texas's federal House seats for the first time since Reconstruction. Democrats in both houses of the Texas Legislature staged walkouts, unsuccessfully trying to prevent the changes. Opponents challenged the plan in three suits, combined when the case went to the United States Supreme Court in League of United Latin American Citizens v. Perry (2006).

<i>Shaw v. Reno</i> 1993 US Supreme Court gerrymandering case

Shaw v. Reno, 509 U.S. 630 (1993), was a landmark United States Supreme Court case in the area of redistricting and racial gerrymandering. After the 1990 census, North Carolina qualified to have a 12th district and drew it in a distinct snake-like manner in order to create a "majority-minority" Black district. From there, Ruth O. Shaw sued this proposed plan with the argument that this 12th district was unconstitutional and violated the Fourteenth Amendment under the clause of equal protection. In contrast, Reno, the Attorney General, argued that the district would allow for minority groups to have a voice in elections. In the decision, the court ruled in a 5–4 majority that redistricting based on race must be held to a standard of strict scrutiny under the equal protection clause and on the basis that it violated the fourteenth Amendment because it was drawn solely based on race.

League of United Latin American Citizens v. Perry, 548 U.S. 399 (2006), is a Supreme Court of the United States case in which the Court ruled that only District 23 of the 2003 Texas redistricting violated the Voting Rights Act. The Court refused to throw out the entire plan, ruling that the plaintiffs failed to state a sufficient claim of partisan gerrymandering.

Georgia v. Ashcroft, 539 U.S. 461 (2003), is a United States Supreme Court case in which the Court found that a three-judge federal district court panel did not consider all of the requisite relevant factors when it examined whether the 2001 Georgia State Senate redistricting plan resulted in retrogression of black voters’ effective exercise of the electoral franchise in contravention of Section 5 of the Voting Rights Act. Section 5, which only applies to those states or political subdivisions that are considered “covered” under Section 4(b) of the VRA, requires that before any change in voting procedure can take effect, it must be precleared by the federal government by a demonstration that the change would not "lead to a retrogression in the position of racial minorities with respect to their effective exercise of the electoral franchise.” The Court held that the district court analysis was incorrect “because it focused too heavily on the ability of the minority group to elect a candidate of its choice in the [safe] districts,” without giving proper consideration to other factors such as the state's creation of additional influence and coalition districts. Accordingly, the Supreme Court vacated and remanded the case to the district court to examine the facts using the new standard announced in its opinion.

<span class="mw-page-title-main">2011 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down fourteen per curiam opinions during its 2011 term, which began October 3, 2011 and concluded September 30, 2012.

Shelby County v. Holder, 570 U.S. 529 (2013), was a landmark decision of the Supreme Court of the United States regarding the constitutionality of two provisions of the Voting Rights Act of 1965: Section 5, which requires certain states and local governments to obtain federal preclearance before implementing any changes to their voting laws or practices; and Section 4(b), which contains the coverage formula that determines which jurisdictions are subject to preclearance based on their histories of discrimination in voting.

<span class="mw-page-title-main">Gerrymandering in the United States</span> Setting electoral district boundaries to favor specific political interests in legislative bodies

Gerrymandering is the practice of setting boundaries of electoral districts to favor specific political interests within legislative bodies, often resulting in districts with convoluted, winding boundaries rather than compact areas. The term "gerrymandering" was coined after a review of Massachusetts's redistricting maps of 1812 set by Governor Elbridge Gerry noted that one of the districts looked like a mythical salamander.

Edward Jay Blum is an American conservative legal strategist known for his activism against affirmative action based on race and ethnicity. He connects potential plaintiffs with attorneys who are willing to represent them in "test cases" which he tries to use to set legal precedents. He is the director of the Project for Fair Representation which he founded in 2005. There is a claim that he is sole member of the Project, but this is disputed by the left. According to its website, the Project focuses specifically on voting, education, contracting, employment, racial quotas, and racial reparations. The Harvard Crimson reported that his work is funded by conservative trusts and foundations, including Donors Trust, the Searle Freedom Trust, the Sarah Scaife Foundation, and The 85 Fund.

<span class="mw-page-title-main">2020 United States redistricting cycle</span>

The 2020 United States redistricting cycle is in progress following the completion of the 2020 United States census. In all fifty states, various bodies are re-drawing state legislative districts. States that are apportioned more than one seat in the United States House of Representatives are also drawing new districts for that legislative body.

Gill v. Whitford, 585 U.S. ___ (2018), was a United States Supreme Court case involving the constitutionality of partisan gerrymandering. Other forms of gerrymandering based on racial or ethnic grounds had been deemed unconstitutional, and while the Supreme Court had identified that extreme partisan gerrymandering could also be unconstitutional, the Court had not agreed on how this could be defined, leaving the question to lower courts to decide. That issue was later resolved in Rucho v. Common Cause, in which the Court decided that partisan gerrymanders presented a nonjusticiable political question.

Rucho v. Common Cause, No. 18-422, 588 U.S. ___ (2019) is a landmark case of the United States Supreme Court concerning partisan gerrymandering. The Court ruled that while partisan gerrymandering may be "incompatible with democratic principles", the federal courts cannot review such allegations, as they present nonjusticiable political questions outside the remit of these courts.

<span class="mw-page-title-main">Redistricting in North Carolina</span>

Redistricting in North Carolina has been a controversial topic due to allegations and admissions of gerrymandering.

Virginia House of Delegates v. Bethune-Hill, 587 U.S. ___ (2019), was a case argued before the United States Supreme Court on March 18, 2019, in which the Virginia House of Delegates appealed against the decision in 2018 by the district court that 11 of Virginia's voting districts were racially gerrymandered, and thus unconstitutional. The Court held the "Virginia House of Delegates lacks standing to file this appeal, either representing the state's interests or in its own right." In other words, the court upheld the decision made by a federal district court ruling in June 2018 that 11 state legislative districts were an illegal racial gerrymander. This was following a previous (2017) case, Bethune-Hill v. Virginia State Bd. of Elections.

Brnovich v. Democratic National Committee, 594 U.S. ___ (2021), was a United States Supreme Court case related to voting rights established by the Voting Rights Act of 1965 (VRA), and specifically the applicability of Section 2's general provision barring discrimination against minorities in state and local election laws in the wake of the 2013 Supreme Court decision Shelby County v. Holder, which removed the preclearance requirements for election laws for certain states that had been set by Sections 4(b) and 5. Brnovich v. Democratic National Committee involves two of Arizona's election policies: one outlawing ballot collection and another banning out-of-precinct voting. The Supreme Court ruled in a 6–3 decision in July 2021 that neither of Arizona's election policies violated the VRA or had a racially discriminatory purpose.

The 2010 United States redistricting cycle took place following the completion of the 2010 United States census. In all fifty states, various bodies re-drew state legislative districts. States that are apportioned more than one seat in the United States House of Representatives also drew new districts for that legislative body. The resulting new districts were first implemented for the 2011 and 2012 elections.

Allen v. Milligan, 599 U. S. 1 (2023), is a landmark United States Supreme Court case related to redistricting under the Voting Rights Act of 1965 (VRA). The appellees and respondants argued that Alabama's congressional districts discriminated against African-American voters. The Court ruled 5–4 that Alabama’s districts likely violated the VRA, maintained an injunction that required Alabama to create an additional majority-minority district, and held that Section 2 of the VRA is constitutional in the redistricting context.

Moore v. Harper, 600 U.S. 1 (2023), is a landmark decision of the Supreme Court of the United States related to independent state legislature theory (ISL), a doctrine that asserts state legislatures have sole authority to establish election laws for federal elections within their respective states without judicial review by state courts, presentment to state governors, and without constraint by state constitutions. The case arose from the redistricting of North Carolina's districts by its legislature after the 2020 United States census, which the state courts found to be too artificial and partisan, and an extreme case of gerrymandering in favor of the Republican Party.

Redistricting in Alabama is the process by which boundaries are redrawn for federal congressional and state legislative districts. It has historically been highly controversial. Critics have accused legislators of attempting to protect themselves from competition by gerrymandering districts.

References

  1. ↑ Tribune, The Texas (November 17, 2011). "Federal Judges Propose Maps for Texas Legislative Races".
  2. ↑ Perry v. Perez , 565 U.S. 388 (2012).
  3. ↑ "Supreme Court throws out court-drawn Texas redistricting maps". January 20, 2012.
  4. ↑ Perez v. Texas, 891F. Supp. 2d808 ( W.D. Tex. 2012).
  5. ↑ "Judges Release Texas Redistricting Maps". News/Talk 95.1 & 790 KFYO. February 29, 2012.
  6. ↑ Texas v. United States (2012), 887F. Supp. 2d133 ( D.D.C. 2012).
  7. ↑ Barnes, Robert (August 28, 2012). "Texas redistricting discriminates against minorities, federal court says" – via www.washingtonpost.com.
  8. ↑ Shelby County v. Holder , 570 U.S. 2 (2013).
  9. ↑ Barnes, Robert (June 25, 2013). "Supreme Court stops use of key part of Voting Rights Act" – via www.washingtonpost.com.
  10. ↑ "Argument preview: Texas redistricting battles return to the court - SCOTUSblog". April 18, 2018.
  11. ↑ Perez v. Abbott, 274F. Supp. 3d624 ( W.D. Tex. 2017).
  12. ↑ Tribune, The Texas (August 24, 2017). "Texas House map must be redrawn, federal court says".
  13. ↑ Liptak, Adam (September 13, 2017). "Splitting 5-4, Justices Put Texas Redistricting on Hold". The New York Times.
  14. ↑ de Vogue, Ariane. "Supreme Court takes up Texas redistricting".
  15. ↑ de Vogue, Ariane (April 24, 2018). "Supreme Court appears closely divided over Texas district maps". CNN . Retrieved April 24, 2018.
  16. ↑ Southern Coalition for Social Justice
  17. 1 2 3 4 Totenberg, Nina (June 25, 2018). "Law: Divided Supreme Court Upholds Nearly All Of Texas GOP Redistricting Plan". National Public Radio. Archived from the original on May 2, 2020. Retrieved May 2, 2020.
  18. ↑ Ebbs, Stephanie (June 25, 2018). "Supreme Court rules one Texas district was racially gerrymandered". ABC News . Retrieved June 25, 2018.
  19. ↑ Prokop, Andrew (June 25, 2018). "Supreme Court splits 5-4 on Texas racial gerrymandering case". Vox.com . Vox.com. Archived from the original on November 9, 2020.
  20. 1 2 "Abbott v. Perez, Opinion of the Court, Part III A at pages 21-22" (PDF). United States Supreme Court. June 25, 2018. Archived from the original (PDF) on November 9, 2020. Retrieved November 14, 2020.
  21. 1 2 Millhiser, Ian (August 13, 2020). "Justice Alito's jurisprudence of white racial innocence". Vox.com . Vox.com. Archived from the original on November 7, 2020. Retrieved November 14, 2020.
  22. 1 2 Howe, Amy (June 25, 2018). "Opinion analysis: Texas scores near-complete victory on redistricting". SCOTUSblog . SCOTUSblog. Archived from the original on November 9, 2020. Retrieved November 14, 2020.
  23. 1 2 3 4 5 Millhiser, Ian (September 18, 2020). "Chief Justice Roberts's lifelong crusade against voting rights, explained". Vox.com . Vox.com. Archived from the original on November 1, 2020. Retrieved November 14, 2020.
  24. 1 2 Stern, Mark Joseph (June 25, 2018). "Jurisprudence: Neil Gorsuch Declares War on the Voting Rights Act". Slate. Archived from the original on March 2, 2021. Retrieved March 6, 2021.
  25. 1 2 3 4 5 6 Millhiser, Ian (October 2, 2020). "The Supreme Court will hear a case that could destroy what remains of the Voting Rights Act". Vox.com . Vox.com. Archived from the original on November 6, 2020. Retrieved November 14, 2020.
  26. ↑ "Voting Rights Enforcement and Reauthorization: The Department of Justice's Record of Enforcing the Temporary Voting Rights Act Provisions" (PDF). U.S. Commission on Civil Rights. May 2006. Archived from the original (PDF) on July 9, 2017. Retrieved August 26, 2018.
  27. ↑ Millhiser, Ian (July 1, 2021). "The Supreme Court leaves the Voting Rights Act alive — but only barely". Vox.com . Vox.com. Archived from the original on June 25, 2023. Retrieved July 2, 2023.
  28. ↑ "United States Code section 52 USC 10301: Denial or abridgement of right to vote on account of race or color through voting qualifications or prerequisites; establishment of violation". Office of the Law Revision Counsel in the U.S. House of Representatives. Archived from the original on November 2, 2020. Retrieved November 14, 2020.
  29. 1 2 Mcdonald, Laughlin (1985). "The Attack on Voting Rights". Southern Changes. 7 (5). Archived from the original on October 14, 2016. Retrieved February 26, 2017.
  30. ↑ PD-icon.svg This article incorporates public domain material from Garrine, Laney (June 12, 2008). The Voting Rights Act of 1965, As Amended: Its History and Current Issues (PDF). Congressional Research Service . Retrieved September 15, 2017.{{citation}}: CS1 maint: multiple names: authors list (link)
  31. ↑ James James Blacksher, Edward Still, Nick Quinton, Cullen Brown, and Royal Dumas. "Voting Rights in Alabama: 1982–2006 (July 2006)" (PDF). protectcivilrights.org. Protect Civil Rights.org. Archived from the original (PDF) on September 24, 2020. Retrieved October 7, 2020.{{cite web}}: CS1 maint: multiple names: authors list (link)
  32. ↑ Epps, Garrett (June 12, 2018). "Politics: The Supreme Court Blesses Voter Purges". The Atlantic. Archived from the original on May 2, 2020. Retrieved May 2, 2020.
  33. ↑ Hasen, Richard L. (June 11, 2018). "Jurisprudence: Sonia Sotomayor's Dissent in the Big Voter-Purge Case Points to How the Law Might Still Be Struck Down". Slate. Archived from the original on May 2, 2020. Retrieved May 2, 2020.
  34. 1 2 Newkirk II, Vann R. (July 10, 2018). "Politics: How Shelby County v. Holder Broke America". The Atlantic. Archived from the original on May 2, 2020. Retrieved May 2, 2020.
This page is based on this Wikipedia article
Text is available under the CC BY-SA 4.0 license; additional terms may apply.
Images, videos and audio are available under their respective licenses.