Supreme Court Sends Alabama Racial Gerrymandering Case Back to Lower Court

The Supreme Court issued a 5-4 ruling yesterday disagreeing with a lower court that had upheld Alabama's racially gerrymandered state legislative redistricting. The cases are Alabama Democratic Conference v. Alabama and Alabama Legislative Black Caucus v. Alabama.

As we discussed in our Term Preview, the Republican-controlled Alabama legislature enacted a state redistricting plan after the 2010 Census that transferred a significant portion of the black population that had previously been in majority-white districts into districts that were already majority-black, a process some have called bleaching. (This plan was adopted while Alabama was still subject to the preclearance provisions of Section 5 of the Voting Rights Act, before Shelby County v. Holder.) Ostensibly to comply with the requirement under Section 5 that new lines not lead to a retrogression in the position of racial minorities with respect to their effective exercise of the electoral franchise, legislators decided that the African American percentages in the redrawn majority-minority districts had to be at least whatever they had become before redistricting. So if a district that was (say) 65% African American in 2002 had become 75% African American by 2010, the new lines had to keep the district at least 75% African American.

Because of population shifts over the past decade and a decision to minimize population differences among districts, this policy meant that African Americans in majority-white districts were redistricted into majority- and supermajority-black districts.

The Alabama Legislative Black Caucus and the Alabama Democratic Conference argued that legislators had misinterpreted Section 5, that race was impermissibly the overriding criterion used by legislators in drawing lines, and that the redistricting plan violated the Fourteenth Amendment. But a special three-judge district court had upheld the redistricting, ruling that (1) minimizing population differences among districts, and not race, was the predominant factor in drawing the lines, so strict scrutiny didn't apply; and (2) even if strict scrutiny applied, the boundaries were narrowly tailored to achieve the compelling purpose of compliance with the preclearance provisions of Section 5 (which was in force then).

In an opinion written by Justice Breyer and joined by the other moderates plus Justice Kennedy, the Supreme Court repudiated the lower court, sending the case back so certain districts can be reanalyzed under the proper standards to determine if they are racially discriminatory. They held that Alabama can't avoid an analysis of whether race was the predominant factor by pointing to its desire to have population balance among districts:

[I]f the legislature must place 1,000 or so additional voters in a particular district in order to achieve an equal population goal, the "predominance" question concerns which voters the legislature decides to choose, and specifically whether the legislature predominately uses race as opposed to other, "traditional" factors when doing so.

Another key part of the ruling was the discussion of Section 5, which the Court made clear does not require a covered jurisdiction to maintain a particular numerical minority percentage. Instead, it requires the jurisdiction to maintain a minority's ability to elect a preferred candidate of choice.

The state's Section 5 rationale seemed like a stretch designed to justify a redistricting process that some have called "bleaching." Yesterday's ruling will ensure that no one grasps for that particular straw again in an effort to cover up racial gerrymandering. (This assumes, of course, that Congress eventually restores Section 5's efficacy by adopting a new formula for coverage, since the Roberts Court struck down the existing formula in the infamous 5-4 Shelby County ruling.) The case is also important because the dissent by the four most right-wing Justices, which was only one vote from becoming the majority opinion, would have allowed the Alabama legislature in this case to use race in drawing districts in a way that would harm minority voters.

PFAW Foundation

Alabama's Shame Grows with Bill to Make It Harder for Gays to Marry

In some parts of the world, government officials won't help you if you don't share their religious beliefs. Citizens seeking to be served by government employees have to go from office to office, experiencing the shame and frustration of being turned away by those whose salaries they pay.

Yesterday, Alabama took a step toward becoming such a place, to the delight of the far right.

The Alabama House passed the so-called "Freedom of Religion in Marriage Protection Act" by an overwhelming margin of 69-25 yesterday. Among its provisions is one stating that civil servants have the right to refuse to perform any civil marriage ceremony should they wish. As reported:

In session today, Rep. A.J. McCampbell, D-Livingston, asked [bill sponsor Jim] Hill: "Why all of a sudden has this become an issue?"

Hill replied: "I can't answer that, sir."

Really? It isn't hard to figure out:

Tears came to the eyes of Rep. Patricia Todd, D-Birmingham, as she spoke against the bill on the House floor. Todd, the only openly gay legislator in the state, said the bill was drafted to discriminate against gay couples who want to marry.

"This is very hurtful to me as an openly gay person," she said.

Ever since a federal district judge ruled that Alabama's marriage ban violates the Constitution, the state has been a showcase of defiance. Alabama Chief Justice Roy Moore violated the canons of judicial ethics in seeking to force government officials from complying with the ruling, prompting our affiliate PFAW Foundation to file a formal complaint with the Judicial Inquiry Commission. Because of Moore, Alabama quickly became a checkerboard where gay and lesbian Alabamans were locked out of full citizenship across vast swaths of the state based on the whims of local officials. The state supreme court then shut down marriages for same-sex couples across the state in a highly controversial ruling.

Now Alabama legislators are seeking to guarantee that even if the U.S. Supreme Court rules that lesbians and gays have the right to marry, it is a right they will not be able to exercise across vast swaths of Alabama, unless they can find a public servant whose religious beliefs do not include a vehement hostility to lesbian and gay equality. That this bill targets one group of people for second class citizenship cannot be seriously questioned. No one should be fooled for a moment that this has anything to do with religious liberty, a fundamental American value designed to be a shield from oppression, not a sword to harm others.


Alabama Supreme Court Orders Probate Judge to Violate Federal Court Decision

Late yesterday saw the latest chapter in the ongoing saga of resistance to marriage equality in Alabama, and it is another ugly one.

Earlier this month, the Alabama Supreme Court (with Chief Justice Roy Moore recused) chose to act on a petition from two far right anti-gay organizations and ruled that the state's marriage ban is constitutional. (In other words, they ruled that gay and lesbian couples do not have a constitutional right to marry in a proceeding where none of the parties was a same-sex couple. How's that for fair?) They ruled that federal district Judge Callie Granade's January decision saying otherwise does not bind anyone but the parties in that case, and they directed every probate judge in the state but one to stop giving marriage licenses to same-sex couples.

The one exception was Probate Judge Don Davis: Since he had been specifically ordered by the federal court to grant a marriage license to the plaintiffs in Strawser v. Strange and Davis, the justices ordered him to say whether he felt that federal court order required him to grant licenses to any other same-sex couples, or only to the parties in that particular case.

Yesterday, the justices (again with Moore recused) concluded that the federal court order didn't apply to any other couples, and they directed Davis to enforce the marriage ban that had been struck down as unconstitutional earlier this year.

It isn't quite clear why the Alabama Supreme Court, rather than Judge Granade, is qualified to say what Judge Grande's order means.

Even putting that aside, the logic of the state justices' legal conclusion is hard to fathom. A federal court ruled that the ban was unconstitutional - period. It did not rule that the ban was unconstitutional only when applied to the particular couples in that lawsuit. When Judge Granade ordered Davis to issue marriage licenses to the plaintiffs who had asked the court for this relief, she clearly intended for Davis to act consistently with the Constitution for any other same-sex couples seeking to marry. For Davis to comply with the Alabama Supreme Court's order, he would have to defy the federal court.

The contempt for the rule of law seen in this order is nothing new to the Alabama high court. After all, Chief Justice Moore himself was removed from the court more than a decade ago for defying a federal district court order. His efforts to nullify the federal marriage equality ruling prompted PFAW Foundation to submit a formal complaint to state ethics officials calling for him to be removed a second time. It is disheartening to see that most of his colleagues on the state high court share his contempt for the rule of law, to say nothing of the rights of lesbian and gay Alabamans.

PFAW Foundation

From Selma to Shelby County to Ferguson

This op-ed was originally published at The Huffington Post.

Fifty years ago in Alabama hundreds of peaceful marchers calling for voting rights were violently attacked by state police. Fifty years later Americans from all walks of life are expected to gather this weekend to mark the anniversary of what became known as Bloody Sunday and embrace the spirit for courage, sacrifice and justice of those women and men who marched, were beaten and no doubt underestimated the impact that their bruises would have on future generations.

The events of that day and the tense days and weeks that followed shocked our national consciousness and became a catalyst for passage of what some call the "crown jewel" of the civil rights movement, the 1965 Voting Rights Act. It's a law that held bipartisan support and helped protect countless Americans from discrimination at the ballot box for almost five decades.

Every year since that bloody day we have honored those 600-plus marchers who put their lives on the line in pursuit of basic democratic rights and racial justice. But this year, with a passion as never before, we must do more than just give lip service. This time marchers of today must clearly connect with the purpose in the pain that started in prayer on a Sunday morning and ended on the Edmund Pettus Bridge in Selma, Alabama, with blood and tears in the afternoon. Why? Because as John Legend so eloquently put it last week, "Selma is now."

The shadow of Bloody Sunday is there, nearly two years after a core provision of the Voting Rights Act was gutted by the Supreme Court in the Shelby County case, as we practice patience for Congress to restore and strengthen what was taken away. When our leaders say that they honor those who refused to turn around, will they also commit to restoring the kinds of voting protections that they were marching for?

Today, 40 bills to restrict voting rights have been introduced in states across the country, from voter ID legislation to proposals reducing access to absentee ballots to bills that would make it more difficult for those with past criminal convictions to vote. When our leaders say they honor those who were beaten and bruised with billy clubs 50 years ago, will they also commit to voting against proposed laws that would make it harder for all people to have an equal voice in our democracy? Will they commit to confirming the highly qualified Loretta Lynch, a woman with a strong commitment to civil rights, to lead -- as the first female African American -- the Justice Department in effectively monitoring and enforcing the voting rights laws we already have and those yet to come?

Today, African Americans and Latinos, especially males, endure being routinely profiled, targeted, and attacked by the police. The report released this week from the Department of Justice about policing in Ferguson, Missouri, revealed that 93 percent of arrests were of African Americans, though they make up only 67 percent of the city's population. It showed and confirmed that African Americans in Ferguson were disproportionately likely to have force used against them by the police. When our leaders say they honor those who were hospitalized for peaceful protest 50 years ago, will they also commit to fighting against discrimination and violence at the hands of those meant to serve and protect our communities?

Selma is now, and the march continues. Selma needed protection for voting rights then, and Selma needs protection for voting rights now. Many civil rights leaders, past and present, and even future leaders, will be in Selma this weekend. But thousands of others who can't be there in person will not be excluded from being a part of a new march. Men and women will with great intent make sure every registered voter gets to the polls to vote in every election, will minister with an activist heart to their neighborhoods when violence upends daily life, will use social media as a tool to motivate participation in work aimed at ending all forms of discrimination in the name of religion, and will organize their communities in active opposition when yet another bill is introduced to undermine, restrict, or deny basic civil and human rights.

On the evening of that Sunday, Dr. Martin Luther King Jr. informed the media that ministers would march and called for clergy from around the country to join them. He said, "The people of Selma will struggle on for the soul of America, but it is fitting that all Americans help to bear the burden. ... In this way all America will testify to the fact that the struggle in Selma is for the survival of democracy everywhere in our land."

I was not there then, but today as with every day, especially because of the Shelby Counties and the Fergusons, I give thanks and will not forget that struggle. On March 7, 1965, the world watched as nonviolent mothers, fathers, students, workers, faith leaders were beaten, tear gassed and hospitalized. On March 7, 2015, let the world watch as this next generation genuinely honors those who had the courage to take a stand that Bloody Sunday "for the survival of democracy." How? By registering, advocating, teaching, speaking up, marching and continuing their work in pursuit of voting rights, freedom, and justice as if our unseen bruises, our lives, our souls depend on it.

PFAW Foundation

The Supreme Court's 2014-2015 Term: PFAW Member Telebriefing

Yesterday, People For the American Way members participated in a telebriefing to discuss the Supreme Court’s upcoming term and to preview some of the important cases the Court will be hearing this year. The call was kicked off by PFAW President Michael Keegan and moderated by PFAW Director of Communications Drew Courtney. PFAW’s Senior Legislative Counsel Paul Gordon reviewed highlights of his recent report previewing the Supreme Court’s upcoming term and answered questions from members. Also on the call and answering questions were Senior Fellow Elliot Mincberg and Executive Vice President Marge Baker.

Among the cases Gordon previewed were Young v. UPS, Integrity Staffing Solutions v. Busk, Mach Mining v. EEOC, Holt v. Hobbs, and Alabama Democratic Conference v. Alabama / Alabama Legislative Black Caucus v. Alabama. The issues addressed in these cases range from employment discrimination and workers’ rights, to religious liberty and voting rights.

He also discussed potential cases that the Court could still add for this term, which included cases on marriage equality, the Affordable Care Act, and contraception coverage by religious nonprofits—the “sequels to Hobby Lobby.”

Members’ questions focused on how the country can move forward to change some of the more damaging decisions like Citizens United, and what each person could do to effect change and impact the courts. Emphasizing what is at stake this election, both PFAW President Michael Keegan and Gordon called on people to vote in November because “when you vote … for the Senate, you are voting for the next Supreme Court justice.”

Listen to the full audio of the telebriefing for more information.



Failing to Defend the Right to Vote Is Simply Not an Option

Earlier this week, on the first anniversary of the Supreme Court's decision in Shelby County v. Holder, the Senate Judiciary Committee took up the important work of restoring the Voting Rights Act of 1965 (VRA). People For the American Way and its African American Ministers in Action program were among the many voting rights advocates who sent a loud and clear message that the VRA is still needed, and the time is now to right what the Court wronged.

As we work to ensure not only that President Obama receives legislation without undue delay, but also that whatever language he signs protects as many voters as possible from discrimination, it is important to remember those who died a half century ago fighting for this very cause.

On June 21, 1964, Michael Schwerner, James Chaney, and Andrew Goodman were murdered in Mississippi while participating in the Freedom Summer campaign to register African Americans to vote.

Today, they are remembered by our friends at Bend the Arc.

Following "Bloody Sunday" on March 7, 1965, Reverend James Reeb traveled to Selma, AL to participate in a second attempt to cross the Edmund Pettis Bridge. On the 9th, he was beaten. On the 11th, he succumbed to his injuries.

Today, members of one of his former congregations, All Souls Unitarian Church in Washington, DC, are "singing on" for change.

Failing to defend the right to vote is simply not an option.

It wasn't then. It isn't now.


Rubio and Sessions Can Prevent Delay of Critical 11th Circuit Vote

Get ready. There’s more Republican obstruction on the way.

The Senate Judiciary Committee has scheduled a vote on 11th Circuit nominee Robin S. Rosenbaum for this Thursday, which is an important step forward in the fight to address our judicial vacancy crisis. Fully a third of the 11th Circuit’s twelve active judgeships are currently vacant, and all four of its empty slots have been declared judicial emergencies by the Administrative Offices of U.S. Courts.

The vacancy crisis in the 11th Circuit is so bad that the court’s chief judge, Edward Carnes, issued an order in December temporarily suspending the standard rule that at least two judges on a three-judge 11th Circuit panel must be members of that court. That means that going forward, two of three judges on these panels could be visiting from someplace else, potentially outvoting the one 11th Circuit judge. It is vital that Judge Rosenbaum be confirmed in a timely manner. And that starts with a timely committee vote.

But it’s unlikely that’s enough reason for GOP Senators to drop their campaign of endless delays for judicial nominations.

Republicans are expected to delay that committee vote using a procedural tactic that they have deployed against all but five of President Obama’s judicial nominees.

That is, unless Sen. Marco Rubio or Sen. Jeff Sessions steps in.

Rosenbaum is from Florida, which gives Rubio a special responsibility to urge Republican senators on the committee not to delay the vote. It is a chance for him to prioritize his constituents over politics. Similarly, Sessions, who represents a state (Alabama) covered by the 11th Circuit, also has a unique responsibility, as a member of the Judiciary Committee, to avoid such needless delay.

Will either Rubio or Sessions step up and help move the process in a more functional direction? We’ll learn on Thursday, but if past events are a predictor of future behavior, I wouldn’t hold my breath.


Representative John Lewis: "There's other bridges to walk across"

Just 11 days ago, on June 14, 2013, Representative John Lewis was honored as a 2013 Progressive Champion by the American Constitution Society for Law and Policy.

Starting at 4:13

Representative Lewis offered an impassioned call to action:

We've come too far. We've made too much progress to stop now or to go back. But we must move forward.

After recalling the ultimate sacrifice made by his contemporaries from the Civil Rights Movement, Representative Lewis continued:

We must be prepared to fight the good fight. And never, ever give up.

He was specifically urging his audience to press on regardless of the Supreme Court's imminent ruling in Shelby County v. Holder, which we now know gutted the Voting Rights Act. Section 5 remains on the books and remains constitutionally valid, but without Section 4, no part of the country is actually covered by Section 5.

As Representative Lewis marks the 50th anniversary of his chairmanship of the Student Nonviolent Coordinating Committee (SNCC), we cannot forget that this is a man who put his life on the line to get the VRA passed in the first place.

On March 7, 1965, what became known as Bloody Sunday, voting rights marchers were beaten in their attempt to cross the Edmund Pettus Bridge in Selma, Alabama. Fifty-eight marchers were treated at a local hospital for their injuries, including then twenty-five-year-old Lewis. It was a tragedy that touched many, including members of what would later become the PFAW Foundation family.

Representative Lewis concluded his ACS remarks with a message to those of us who weren't there that day in Selma:

You didn't walk across the bridge, but there's other bridges to walk across.

The Supreme Court's ruling in Shelby is a setback, or as Representative Lewis put it to ABC's Jeff Zeleny earlier today:

What the Supreme Court did was to put a dagger in the very heart of the Voting Rights Act of 1965.

But it's also part of the voting rights bridge that we must continue fighting to get across.

PFAW Foundation

Supreme Court to Review Voting Rights Act

The Supreme Court announced today that it will accept a case arguing that Section 5 of the Voting Rights Act is unconstitutional: Shelby County v. Holder. Given the hostility of the Roberts Court's conservatives to voting rights and minority rights, this was not a surprise.

Since its adoption in 1965, Section 5 of the Voting Rights Act has been an essential protection against those who seek to deny Americans the right to vote based on race. Congress specified areas of the country with a history of discrimination where, in its judgment, any changes in voting laws would need federal approval before going into effect, either from the Justice Department or from a federal court. The Supreme Court upheld this as constitutional in 1966. Congress has reauthorized the VRA several times since then, most recently in an overwhelming vote in 2006. After considering the history of voter suppression in the years leading up to the most recent reauthorization, Congress chose not to alter the list of states and counties subject to Section 5 preclearance. As recently as 2009, the Court declined to rule on Section 5's constitutionality when it was raised in a case called Northwest Austin Municipal Utility District Number One [NAMUDNO] v. Holder.

These past few months have seen a number of examples showing the vital role Section 5 plays in protecting the right to vote. Due to preclearance, a discriminatory redistricting scheme adopted by Texas, a Texas voter ID law with a racially discriminatory impact, and a severe cutback in early voting that disproportionately hurt minority voters in several Florida counties were all prevented from going into effect. Without Section 5, the discrimination and damage would occur before voters could go to court to try to stop it; they would have had a harder time enjoining enforcement of such laws, which could have remained in effect throughout the long months or years of litigation.

Far-right opponents of the Voting Rights Act note that racial discrimination in voting rights in the mostly southern states covered by Section 5 is not rampant as it was in the 1960s. (Hmmm, could Section 5 itself have something to do with that?) They argue that Congress's decision in 2006 to maintain the same list of covered areas from 1965, regardless of changes in intervening decades, was unconstitutional. Specifically, they argue that it exceeds congressional authority under the 15th Amendment (preventing denial of the right to vote based on race), violates the states' rights to regulate elections under Article IV and the 10th Amendment.

In announcing that it will hear the case, the Court threw another factor into the mix. The question it asked parties to brief was slightly different from what the plaintiffs asked for:

Whether Congress' decision in 2006 to reauthorize Section 5 of the Voting Rights Act under the pre-existing coverage formula of Section 4(b) of the Voting Rights Act exceeded its authority under the Fourteenth and Fifteenth Amendments and thus violated the Tenth Amendment and Article IV of the United States Constitution. (emphasis added to show new issue)

Many Court watchers expected the Court to strike down Section 5 in 2009 in the NAMUDNO case, but it declined then to address the constitutional issue. Clearly, the Court's conservatives feel it is time to do so.

In the 1950s and 1960s, many brave Americans gave their lives so that African Americans would no longer be denied the right to vote. The Voting Rights Act – and especially Section 5 – was the triumph of the best of American principles over the worst of American racism, often couched as "states' rights." By next June, we will learn whether Section 5 will fall before that all-too familiar altar of "states' rights."

PFAW Foundation

UPDATE: State legislation shines national spotlight on voter ID

UPDATE: Back in March, we turned our attention to the 47th anniversary of Bloody Sunday. In the months since, we’ve crisscrossed the nation and detailed how the fights of 50 years ago are being resurrected today. The Atlantic’s Andrew Cohen yesterday offered his own telling, invoking Dr. King’s famous quote, “The arc of the moral universe is long but it bends towards justice,” to break down the dangerous myths and machinations of voter suppression, concluding that “[t]hese new laws seek to bend the arc backward again, to take away from people their effective right to vote.” It’s important that we remain vigilant over the next nine weeks, so that on November 6 eligible Americans are able to cast a vote and have it count. In the words of LBJ, “Then with his vote and his voice he is equipped with a very potent weapon to guarantee his own dignity.” Click here and here for more from Andrew Cohen.

March 7, 2012 marked the 47th anniversary of the “Bloody Sunday” when voting rights marchers were beaten in their attempt to cross the Edmund Pettus Bridge in Selma, Alabama.

NAACP President Ben Jealous joined activists from then and now in marking the occasion with another march, saying protest is just as necessary now as it was then.

"We need people to understand that not only is history not very distant, but we stand on the precipice of repeating it," Jealous said.

The NAACP leader said strict voter ID laws that won't allow people to vote without a driver's license or passport are unnecessary and will make it difficult -- and in some cases impossible -- for 5 million people to vote.

"We need to make sure that the principle of one person, one vote, is respected," he said.

Last fall’s The Right to Vote under Attack: The Campaign to Keep Millions of Americans from the Ballot Box, a Right Wing Watch: In Focus report by PFAW Foundation, details how the fights of 50 years ago are being resurrected today. Indeed we’ve seen the strict laws that Jealous mentions pushed in states including Virginia, Michigan, Minnesota, Wisconsin, New Hampshire, Pennsylvania, and Texas, among others, along with the rise of the American Legislative Exchange Council.

Following what happened in Virginia, Washington Post editorialized against strict ID.

Even if Republican lawmakers aren’t personally acquainted with people who don’t carry ID, they exist. And provided they are legally registered to vote, they should be allowed to cast their ballots — without encumbrances manufactured by the state.

Ari Berman wrote in Rolling Stone about what he believes are the political motivations and consequences.

March 2012:

Since the 2010 election, Republicans have waged an unprecedented war on voting, with the unspoken but unmistakable goal of preventing millions of mostly Democratic voters, including students, minorities, immigrants, ex-convicts and the elderly, from casting ballots in 2012. More than a dozen states, from Texas to Wisconsin and Florida, have passed laws designed to impede voters at every step of the electoral process, whether by requiring birth certificates to register to vote, restricting voter registration drives, curtailing early voting, requiring government-issued IDs to cast a ballot, or disenfranchising ex-felons.

Within days, the crucial battlegrounds of Pennsylvania and Virginia will become the latest GOP states to pass legislation erecting new barriers to voting. If, as expected, the new laws lead to fewer Democrats casting ballots in November, both states could favor Republicans, possibly shifting the balance of power in Congress and denying Barack Obama a second term.

August 2011:

Republicans have long tried to drive Democratic voters away from the polls. "I don't want everybody to vote," the influential conservative activist Paul Weyrich told a gathering of evangelical leaders in 1980. "As a matter of fact, our leverage in the elections quite candidly goes up as the voting populace goes down." But since the 2010 election, thanks to a conservative advocacy group founded by Weyrich, the GOP's effort to disrupt voting rights has been more widespread and effective than ever. In a systematic campaign orchestrated by the American Legislative Exchange Council – and funded in part by David and Charles Koch, the billionaire brothers who bankrolled the Tea Party – 38 states introduced legislation this year designed to impede voters at every step of the electoral process.

Then there’s Roll Call.

Rock the Vote is one of several dozen organizations, from civil rights groups to Latino, labor and women’s groups, that have launched a multipart campaign to push back against new registration rules for voters that have been enacted in many states. The fight over voter access has triggered state-level lobbying, ballot initiatives and lawsuits, and the issue will likely land before the Supreme Court.

Voting rights activists are responding to a wave of state laws enacted after the 2010 elections, which ushered in GOP majorities in more than two dozen state legislatures. Voting rights advocates have struggled to gain traction amid public indifference and more visible collective bargaining fights, but they are starting to win attention at the Justice Department and on Capitol Hill.

However voter ID is resolved, it’s clear that it’s an issue of national concern, not one isolated to a few states.

Or even international. Jealous and the NAACP have put the issue before the United Nations Human Rights Council. Click here to read their report, Defending Democracy: Confronting Modern Barriers to Voting Rights in America.

PFAW Foundation