Protecting and Promoting Native American Voting Rights

By Gregory Perryman

High School Essay Contest Winner

From a policy of genocide to assimilation, it is difficult to separate the long history of oppression by the United States Government from the struggle for voting rights by Native Americans. It was not until recent history that Native Americans were given citizenship under the 1924 Indian Citizenship Act and thus the right to vote after being excluded from the 14th and 15th amendments. It would not be until the year 1948 that two breakthrough cases Trujilo vs Garley in New Mexico and Harrison vs Laveen in Arizona, that Native Americans were able to vote in state and federal elections in each state respectively. Utah would be the last state to repeal laws barring Indigenous people from voting completely. They did so in reaction to the appeal of Allen v Merrell to the Supreme Court which the Utah state legislature thought would surely strike down the law. In 1965 the VRA passed extending its protections to Native Americans who were subject to suppression tactics a lot like those used in the south against Black voters such as literacy tests. 

“‘Native people need to have a seat at the table...I mean, it’s 2020 for heaven’s sake…They deserve to have their voices heard.’”commented Deb Halland, a congresswoman from New Mexico and soon to be the first Native American cabinet secretary as Secretary of the Interior. She is speaking concerning voting rights and representation for 6.8 million Native Americans and Alaskan Natives living in the US, many citizens of the 574 federally recognized tribes. There are nearly 4.7 million Native American eligible voters, of which only 66% are registered. Average turnout is five to fourteen percent, the lowest of any racial group in the US. However, Native American voters have proven to be both powerful and decisive in numerous elections like that of Hedi Heitkamp of North Dakota's 2012 senatorial election where she won by less than 3,000 votes. Following Shelby County vs Holder, a new landscape of voter suppression has emerged that puts the burden on Tribes and nonprofit organizations to litigate and uphold the promises of the Voting Rights Act (VRA) on issues related to language access, voter identification, and numerous other laws that suppress the vote. The promotion of Native American voting rights is crucial to confronting the oldest contradiction of the American republic. Many battles have been won recently due to the hard work of Native American activism, however, there is still a long way to go to realize the coexistence of self-determination and the franchise for the original inhabitants of this land. 

In 2013 when the Supreme Court in Shelby County vs Holder struck down section 4(b) and as a result the preclearance measure in section 5 the protections that were extended to Native Americans residing in states like Arizona gave way to a new intensified wave of voter suppression. Though Section 2 of the VRA is still in effect, Shelby County vs Holder “reverses the burden of proof, requiring the federal government, citizens, and advocates to prove the voting change is discriminatory…” putting an enormous strain on tribes with over 1 million dollars for litigation to have a chance at success. 

Bilingual language access in elections was mandated under section 203 of the 1975 amendment to the VRA and later expanded in 1992. Native Alaskan tribes have had to litigate for language access at the ballot box most notably in the case Toyukak v. Treadwell, No. 3:13-cv-00137- SLG, (D. Alaska Sept. 30, 2015). This case found that Alaska had failed to provide significant language assistance to Alaskan native tribes specifically through pre-election materials detailing what was on the ballot. Mr. Mike Toyukak himself would take the stand in a contentious trial demonstrating Alaskan Native voters “had experienced exclusion from not just one or two pieces of voting information...but exclusion from the entire political process”.

Another barrier to voting that Native American voters face is increasingly strict voter ID requirements. North Dakota in 2013 implemented a strict voter ID law which eliminated the practice of allowing voters to swear their identity using a signed affidavit or being vouched for by a poll worker they knew. Instead, IDs require you to provide a county or state-recognized address which Native American reservations often lack. Many Native Americans use P.O. boxes to receive mail, and with high poverty rates often are without a stable address. The impact likely intended is that a whole swath of voters living on reservations are disenfranchised. To rectify this issue tribes like The Turtle Mountain Band of Chippewa Indian had to surge resources spending $36,000 to provide 2,400 new ID cards which cost $15, waiving the fee to avoid forcing citizens to choose between a “week’s worth of milk and bread”and voting.In Spirit Lake Tribe. v. Jaeger, No. 1:18-cv- 00222 (D.N.D.) (Complaint filed Oct. 30, 2018) the situation was similar. The Spirit Lake and Standing Rock tribes reached a consent decree with the North Dakota Secretary of State to allow Native American voters to verify their place of residence on a map and provide free state ID’s on reservations 30 days before each election. Though this was a positive breakthrough, many states such as Arizona have increasingly strict voter ID laws that disenfranchise Native American voters. Defending the constitutional right to vote for indigenous people can not be done in the courts alone.

The way forward on combating voter suppression and strengthening voting rights for Native American voters is clear. Washington state passed the Native American Voting Rights Act in 2019 and currently the John Lewis Voting Rights Act and Native American Voting Rights Act sit stalled in Congress. The biggest impediment: political incentives that discourage fulfilling the fullest vision of democracy in order to prevent Native American tribes and citizens from having both self-determination and a say in the affairs of a nation that has for so long tried to erase them.

Endnotes

[1] Marcia L Fudge, “Voting Rights and Election Administration in the United States of 

America,” Voting Rights and Election Administration in the United States of America § 

(2019).

[2] Sarah Rounsville, “Trujillo v. Garley: The Struggle for Native American Voting Rights,” 

Intermountain Histories (Brigham Young University, 2019), https://www.intermountainhistories.org/items/show/251.

[3] Jennifer Robinson, “Utah and Native American Voting Rights,” Utah Women's History 

(Better Days Curriculum, May 2, 2019), https://www.utahwomenshistory.org/2019/03/utah-and-native-american-voting-rights/.

[4] Nathan Rott, “In Historic Move, Biden To Pick Native American Rep. Haaland As Interior 

Secretary,” NPR (NPR, December 17, 2020), https://www.npr.org/2020/12/17/937259525/in-historic-move-biden-to-pick-native-american-rep-deb-haaland-as-interior-secre.

[5]  Dr. James Thomas Tucker, Jacqueline De León, and Dr. Dan McCool, “Obstacles at Every 

Turn,” Native American Voting Rights (Native American Rights Fund , June 18, 2020), https://vote.narf.org/obstacles-at-every-turn/, 6.
{6] Marcia L Fudge, “Voting Rights and Election Administration in the United States of 

America,” Voting Rights and Election Administration in the United States of America § (2019).

[7] James Thomas Tucker, Natalie A Landreth, and Erin Dougherty Lynch, “‘Why Should I Go 

Vote Without Understanding What I Am Going to Vote For?’ The Impact of First Generation Voting Barriers on Alaska Natives,” Michigan Journal of Race & Law 22, no. 327 (2017), https://doi.org/10.36643/mjrl.

[8] Marcia L Fudge, “Voting Rights and Election Administration in the United States of 

America,” Voting Rights and Election Administration in the United States of America § (2019).

[9] Georgia Lyon, “Spirit Lake Tribe, Et Al. v. Jaeger,” Campaign Legal Center, April 24, 2020, 

https://campaignlegal.org/cases-actions/spirit-lake-tribe-et-al-v-jaeger.

[10] Seattle Weekly, “Native American Voting Rights Act Signed into Law,” Seattle Weekly, 

March 18, 2019, https://www.seattleweekly.com/news/native-american-voting-rights-act-signed-into-law/.

[11] (2020), https://www.congress.gov/bill/116th-congress/senate-bill/4263/text.

[12](2019),https://www.congress.gov/bill/116th-congress/house-bill/1694/text?q=%7B%22searc

h%22%3A%5B%22H.+R.+83%22%5D%7D&r=62&s=1.

Bibliography

John Lewis Voting Rights Advancement Act. Bill, Congress.Gov § (2020). 

https://www.congress.gov/bill/116th-congress/senate-bill/4263/text. 

Lyon, Georgia. “Spirit Lake Tribe, Et Al. v. Jaeger.” Campaign Legal Center, April 24, 2020. 

https://campaignlegal.org/cases-actions/spirit-lake-tribe-et-al-v-jaeger. 

Native American Voting Rights Act of 2019. Bill, Congress.gov § (2019). 

https://www.congress.gov/bill/116th-congress/house-bill/1694/text?q=%7B%22search%22%3A%5B%22H.+R.+83%22%5D%7D&r=62&s=1. 

Robinson, Jennifer. “Utah and Native American Voting Rights.” Utah Women's History. 

Better Days Curriculum, May 2, 2019. https://www.utahwomenshistory.org/2019/03/utah-and-native-american-voting-rights/. 

Rott, Nathan. “In Historic Move, Biden To Pick Native American Rep. Haaland As Interior 

Secretary.” NPR. NPR, December 17, 2020. https://www.npr.org/2020/12/17/937259525/in-historic-move-biden-to-pick-native-american-rep-deb-haaland-as-interior-secre. 

Rounsville, Sarah. “Trujillo v. Garley: The Struggle for Native American Voting Rights.”

Intermountain Histories. Brigham Young University, 2019. https://www.intermountainhistories.org/items/show/251. 

Seattle Weekly. “Native American Voting Rights Act Signed into Law.” Seattle Weekly, March 

18, 2019. https://www.seattleweekly.com/news/native-american-voting-rights-act-signed-into-law/. 

Tucker, Dr. James Thomas, Jacqueline De León, and Dr. Dan McCool. “Obstacles at Every 

Turn.” Native American Voting Rights. Native American Rights Fund , June 18, 2020. https://vote.narf.org/obstacles-at-every-turn/. 

Tucker, James Thomas, Natalie A Landreth, and Erin Dougherty Lynch. “‘Why Should I Go 

Vote Without Understanding What I Am Going to Vote For?’ The Impact of First Generation Voting Barriers on Alaska Natives.” Michigan Journal of Race & Law 22, no. 327 (2017). https://doi.org/10.36643/mjrl. 

United States House of Representatives Committee on House Administration Subcommittee on 

Elections, and Marcia L Fudge. Report, Voting Rights and Election Administration in the United States of America § (2019). 

Why Voter Suppression in the 2020 Election Didn’t Surprise Anyone

By Ian Park

High School Essay Contest Runner-Up

Equity and politics don’t often go hand-in-hand. The 2020 presidential election was no exception, and with the COVID-19 pandemic shaking up the traditional electoral process, an unprecedented number of mail-in and absentee ballots helped dictate this year’s election results. As a result, there have been many attempts, particularly by the Republican party, to delegitimize the voting power of certain demographics. However, voter suppression is far from a new phenomenon — it’s an age-old tactic that has been used by many political parties on both sides of the spectrum to systematically repress minority votes to influence elections in a more “subtle” way than literal ballot stuffing. The legal precedent for voter suppression is concerning, and the government has long been complacent in holding perpetrators accountable.

The history of Black voter suppression in America dates back to the 19th century, when Jim Crow laws introduced poll taxes, literacy tests, the Grandfather Clause, and more. Even the Supreme Court in 1937’s Breedlove v. Suttles upheld Georgia’s poll taxes.[1] The Court’s majority opinion at the time parallels the same faulty rhetoric we see today — that just because a system or law applies to all citizens, it isn’t unconstitutional or discriminatory. However, the entire premise of devices such as the poll tax was to disproportionately impact Black citizens, who were more likely to be unable to pay the tax, and hence, unable to vote. To make matters worse, organizations such as the Ku Klux Klan also forcibly intimidated Black voters, often staking out polling stations and distributing threatening leaflets in Black neighbourhoods.[2]  

But what does voter suppression look like in the 21st century? 
The story of voter suppression today starts with the 2000 presidential election, where last-minute recount controversies in Florida further complicated an already hotly contested presidential election. The US Civil Rights Commission found that during recounts, election supervisors often used flawed felon databases where Black voters were more likely to have prior convictions. As a direct result, Black voters were 10 times more likely than white voters to have had their ballots purged, and “Poorer countries, particularly those with large minority populations, were more likely to use voting systems with higher spoilage rates than more affluent counties with significant white populations.”[3] Eventually, Bush v. Gore declared that recounts would be stopped, but the damage was already done. The Republican party had successfully delegitmize normal election institutions, such as the methods that were used to manually recount votes. 

Another blow to voter rights came in 2013’s Shelby County v. Holder, when the Supreme Court declared Section 4 of the Voting Rights Act of 1965 unconstitutional. The ruling overturned Section 4a of the Act, which identified regions of the country where racial discrimination in voting was prevalent and prevented the use of “a test or device,” in determining voter eligibility.[4] It also overturned Sections 4e and 4f, which protected the ballot of those with limited English proficiency. 

Aside from blatant voter purges and the repeal of key voter protections, many of the same intimidation tactics employed during the Reconstruction Era by white supremacists are still used today, with reports of armed “poll watchers” at polling stations and caravans of Trump supporters taking to the street.[5] More recently this November, voters have been turned away from the polls for wearing Black Lives Matter shirts.[6] Ballot drop boxes in Los Angeles and Boston have also been burned, invalidating hundreds of votes.[7] 

In addition, Gerrymandering, the process of redrawing district lines, can either dilute or over-saturate the influence of a community’s vote. This process is often carried out by the political party in control of a state’s legislature. Gerrymandering often targets districts by demographics, packing low-income or nonwhite communities to “bleach,” or saturate surrounding communities with white voters whose ballots are ultimately more influential. According to a study conducted by the Center for American Progress, Gerrymandering flipped an average of 59 seats in the House of Representatives during recent elections.[8] If that wasn’t concerning enough, the Supreme Court ruled in 2019’s Rucho v. Common Cause that federal courts must stay out of partisan disputes over district lines. Once again, America’s judiciary chose to perpetuate disenfranchisement instead of addressing a centuries-long problem.

Although BIPOC communities have most often been the target of voter suppression, other demographics, such as low-income communities and convicted felons, are also frequently disenfranchised. For low-income voters, voter ID requirements in many states are barriers because many cannot afford costly forms of accepted identification. In 48 states, felons can’t vote while incarcerated, and until recently in states like Florida, Alabama, and Iowa, they were permanently barred from voting. Currently, there are more than six million disenfranchised felons, and it’s no surprise that it’s the minorities in these states’ prison systems that bear the brunt of this exclusion. A shocking one in 13 African Americans of voting age is disenfranchised, a rate which is more than four times greater than that of non-African Americans.[9]

And despite all of these affronts to the spirit of democracy, America continues to pride itself in its unfaltering political process and protection of basic civil rights. 

An unobstructed democratic vote is a key pillar of American democracy, and institutionalized voter suppression in its many forms must be addressed by confronting wrongdoers at all levels of involvement. More legislation such as the John R. Lewis Voting Rights Act of 2020 (which proposes to revise the preclearance formulas from the original 1965 VRA ruled unconstitutional in Shelby County v. Holder) as well as committees to investigate and prosecute reports of voter suppression, must be established. Empirically, legislation protecting voting rights without strong backing has had little effect. For instance, the Ku Klux Klan Act of 1871 had little effect after the end of the Union’s Reconstruction-era military occupation of the South. Thus, in a new era of highly polarized and identity-based American politics, it’s more important than ever for the government to step up and ensure that the age of state-sanctioned disenfranchisement is over.

Endnotes

1. “BREEDLOVE v. SUTTLES, Tax Collector.” Legal Information Institute. Legal Information Institute. Accessed January 10, 2021. https://www.law.cornell.edu/supremecourt/text/302/277  

2. Bump, Philip. “The Long History of Black Voter Suppression in American Politics.” The Washington Post. WP Company, April 29, 2019. https://www.washingtonpost.com/news/the-fix/wp/2016/11/02/the-long-history-of-black-voter-suppression-in-american-politics/.  

3. U.S. Commission on Civil Rights. “Voting Irregularities in Florida During the 2000 Presidential Election.” Chapter 9: Findings and Recommendations, June 2001. https://www.usccr.gov/pubs/vote2000/report/ch9.htm.   

4. “SHELBY COUNTY v. HOLDER.” Legal Information Institute. Legal Information Institute. Accessed January 10, 2021. https://www.law.cornell.edu/supremecourt/text/12-96.   

5. Rose, Joel. “As Pro-Trump Caravans Hit Roads Across U.S., Organizers Are Upbeat Despite Tensions.” NPR. NPR, September 24, 2020. https://www.npr.org/2020/09/24/916497045/as-pro-trump-caravans-hit-roads-across-u-s-organizers-are-upbeat-despite-tension.  

6. CBS/Associated Press. “Memphis Poll Worker Fired for Turning Away Voters with ‘Black Lives Matter’ Shirts.” CBS News. CBS Interactive, October 20, 2020. https://www.cbsnews.com/news/poll-worker-fired-turning-away-voters-wearing-blm-shirts/.  

7. Richer, Alanna Durkin. “Man Charged in Burning of Ballot Drop Box in Boston.” ABC News. ABC News Network, October 26, 2020. https://abcnews.go.com/Politics/wireStory/man-charged-burning-ballot-drop-box-boston-73837313.   

8. Tausanovitch, Alex. “Voter-Determined Districts.” Center for American Progress, May 9, 2019. https://www.americanprogress.org/issues/democracy/reports/2019/05/09/468916/voter-determined-districts/.  

9. Uggen, Christopher, Ryan Larson, and Sarah Shannon. “6 Million Lost Voters: State-Level Estimates of Felony Disenfranchisement, 2016.” The Sentencing Project, October 6, 2020. https://www.sentencingproject.org/publications/6-million-lost-voters-state-level-estimates-felony-disenfranchisement-2016/.  

Bibliography

1. “BREEDLOVE v. SUTTLES, Tax Collector.” Legal Information Institute. Legal Information Institute. Accessed January 10, 2021. https://www.law.cornell.edu/supremecourt/text/302/277  

2. Bump, Philip. “The Long History of Black Voter Suppression in American Politics.” The Washington Post. WP Company, April 29, 2019. https://www.washingtonpost.com/news/the-fix/wp/2016/11/02/the-long-history-of-black-voter-suppression-in-american-politics/.  

3. U.S. Commission on Civil Rights. “Voting Irregularities in Florida During the 2000 Presidential Election.” Chapter 9: Findings and Recommendations, June 2001. https://www.usccr.gov/pubs/vote2000/report/ch9.htm.   

4. “SHELBY COUNTY v. HOLDER.” Legal Information Institute. Legal Information Institute. Accessed January 10, 2021. https://www.law.cornell.edu/supremecourt/text/12-96.   

5. Rose, Joel. “As Pro-Trump Caravans Hit Roads Across U.S., Organizers Are Upbeat Despite Tensions.” NPR. NPR, September 24, 2020. https://www.npr.org/2020/09/24/916497045/as-pro-trump-caravans-hit-roads-across-u-s-organizers-are-upbeat-despite-tension.  

6. CBS/Associated Press. “Memphis Poll Worker Fired for Turning Away Voters with ‘Black Lives Matter’ Shirts.” CBS News. CBS Interactive, October 20, 2020. https://www.cbsnews.com/news/poll-worker-fired-turning-away-voters-wearing-blm-shirts/.  

7. Richer, Alanna Durkin. “Man Charged in Burning of Ballot Drop Box in Boston.” ABC News. ABC News Network, October 26, 2020. https://abcnews.go.com/Politics/wireStory/man-charged-burning-ballot-drop-box-boston-73837313.   

8. Tausanovitch, Alex. “Voter-Determined Districts.” Center for American Progress, May 9, 2019. https://www.americanprogress.org/issues/democracy/reports/2019/05/09/468916/voter-determined-districts/.  

9. Uggen, Christopher, Ryan Larson, and Sarah Shannon. “6 Million Lost Voters: State-Level Estimates of Felony Disenfranchisement, 2016.” The Sentencing Project, October 6, 2020. https://www.sentencingproject.org/publications/6-million-lost-voters-state-level-estimates-felony-disenfranchisement-2016/.  

How the Supreme Court Perpetuates the Double Standard

By Aryan Ranjan

High School Essay Contest 3rd Place

From Patrick Henry’s glorious ultimatum of liberty or death to the colonists’ valiant display of defiance against the Tea Act at Griffin’s Wharf in 1773, the very premise of American patriotism has always stemmed from riots and protests – the will to reject the status quo by any means necessary to fight for real, beneficial change. Unfortunately, if there’s one thing that has become evident since the storming of our nation’s Capitol just days ago, it's that even this hallmark of our democracy is prejudiced. As predominantly white Americans fought through barricades armed with pipe bombs and nooses, law enforcement met them with selfies and hand-holding; yet, when millions of Black Americans marched through the streets, fighting for their very livelihoods, they were violated with rubber bullets and batons.[1]

However, this double standard is anything but new for minority communities, especially when it comes to voter integrity. To this, we can look to the Fifteenth Amendment, which had noble intentions but was easily circumvented. Although the Amendment prohibited the denial of voting rights on the basis of race or skin color, it conveniently left it up to the states to oversee elections in any manner they saw fit.[2] In Mississippi, this meant launching a series of poll taxes and literacy tests in the hopes of intimidating Black voters. And when challenged on this blatant abuse of power in the case of Williams v. Mississippi, 170 U.S. 213 (1898), the Supreme Court upheld the state’s rules, touting that even though the measures reduced Black voter registration rates to nearly zero, they did not violate the Constitution because the language of the disenfranchisement measures were race-neutral: both White and Black men were affected by the tests, illustrating that neither side was specifically targeted.[3] With such a faulty precedent set in place, numerous Southern states followed suit, leading to a slippery slope of the Jim Crow laws which weren’t eliminated until the Voting Rights Act of 1965 (VRA). 

According to the US Commission on Civil Rights, the VRA was quite effective, as black voter registration rates in Mississippi increased from 6.7% in 1965 to 59.8% in 1967.[4] Unfortunately, the protections granted by the VRA were soon gutted when Section 4 was ruled unconstitutional, in Shelby County v. Holder U.S. 529 (2013). Writing the majority opinion, Chief Justice Roberts used the same mentality as Justice McKenna in Williams v. Mississippi, arguing that there was no sign of prejudice directed specifically towards Black Americans anymore; what was prejudicial, however, was the VRA’s treatment of states with a history of disenfranchising Blacks.[5] Since the Department of Justice could no longer monitor “covered jurisdictions,” Section 5 of the VRA essentially became moot – states were now free to enact much stronger restrictions on minority voters without the Attorney General’s approval. Just like that, Jim Crow 2.0 came into full effect.

Just a month after the case’s ruling, North Carolina’s State Legislature requested and received racial data from across the state to change its voting requirements. After analyzing the data, a new bill was passed, maintaining only the IDs that white North Carolinians were more likely to possess, eliminating the first week of early voting, and removing one of the two “souls-to-the-polls” Sundays in which African American churches provided transportation to voters.[6] Although the US Court of Appeals held that this law specifically targeted African Americans, the actions taken in North Carolina opened the floodgates for more exploitation, spotlighting the fundamental flaw in Chief Justice Roberts’s reasoning to vote against the VRA in the first place.  

Unfortunately, the cases of voter suppression didn’t just stop there. In 2018, the Supreme Court’s ruling in Husted v. A. Philip Randolph Institute No. 16-980, U.S. 584 (2018) upheld an Ohio law allowing states to purge names from voting rolls if those persons had not voted recently.[7] The inherent harms of this ruling can be seen by Virginia’s actions in 2013, in which officials purged nearly 39,000 voters based on data that was later found to have an error rate of up to 17%.[8] Then, in terms of partisan gerrymandering, the Supreme Court ruled in Rucho v. Common Cause No. 18-422, U.S. 588 (2019) that federal courts could not review challenges to heavily political issues, instead leaving the decision up to the individual states. This opened the doors for lower court judges to to allow new restrictions on voting, leading to the Seventh Circuit upholding efforts by Wisconsin Republicans to limit early voting even after a district court found that early voting hours were cut to suppress the reliably Democratic vote of Milwaukee’s African American population.[9] Not to mention, in Alabama, legislators closed down nearly thirty-six DMV offices in eight of the ten Alabama counties with the highest percentage of non-white voters to prevent their votes from being counted to the fullest extent.[10] All together, fourteen states have enacted stricter voter restrictions since Shelby County making it difficult and confusing to vote.

Given these statistics, there should be no surprise as to why America ranks lower than any other long-established democracy in terms of election integrity.[11] With over eight-hundred polling places being closed prior to the 2016 election nationwide, experts believe that even the Presidential Election was overturned largely due to voter suppression. In a country where every single bill, law, and letter is inked in the name of equality itself, this is truly unacceptable and the Supreme Court must take immediate action to ensure that our democracy is no longer undermined by selfish politicians who care more about their reelections than the wellbeing of their constituents.

It’s still important to acknowledge that true equity is not going to come by merely pointing out where the injustices lie. True equity will come by fighting for what is right. By continuing the legacy of our Founding Fathers and rejecting these social norms, we can bring back the essence of our democracy – as Americans.

Endnotes

[1] Feis, Aaron. "Two Capitol cops suspended in riot probe, congressman says." New York Post. Last modified January 11, 2021. Accessed January 11, 2021. https://nypost.com/2021/01/11/two-capitol-cops-suspended-one-law-enforcement-member-arrested-pol/.

[2] "A History of Voter Suppression." National Low Income Housing Coalition. Last modified October 31, 2020. Accessed January 11, 2021. https://nlihc.org/resource/history-voter-suppression.

[3] Mckeever, Amy. "Voter suppression has haunted America since it was founded." National Geographic. Last modified August 21, 2020. Accessed January 11, 2021. https://www.nationalgeographic.com/history/reference/united-states-history/voter-suppression-haunted-united-states-since-founded/.

[4] Lopez, German. "How the Voting Rights Act transformed black voting rights in the South, in one chart." Vox. Last modified March 6, 2015. Accessed January 11, 2021. https://www.vox.com/2015/3/6/8163229/voting-rights-act-1965.

[5] Serwer, Adam. "The Supreme Court Is Helping Republicans Rig Elections." The Atlantic. Last modified October 22, 2020. Accessed January 12, 2021. https://www.theatlantic.com/ideas/archive/2020/10/dont-let-supreme-court-choose-its-own-electorate/616808/.

[6] "The Effects of Shelby County v. Holder." Brennan Center for Justice. Last modified October 2, 2019. Accessed January 12, 2021. https://www.brennancenter.org/our-work/policy-solutions/effects-shelby-county-v-holder.

[7] HUSTED, OHIO SECRETARY OF STATE v. A. PHILIP RANDOLPH INSTITUTE, 584 S. Ct. (June 11, 2018).

[8] "Virginia Election Officials Purging Almost 40000 Voters." The Washington Post. Last modified October 18, 2013. Accessed January 11, 2021. https://www.washingtonpost.com/blogs/govbeat/wp/2013/10/17/virginia-election-officials-purging-almost-40000-voters/.

[9] Neuman, Scott. "Federal Court In Wisconsin Upholds Voting Restrictions Favored By Republicans." NPR. Last modified July 1, 2020. Accessed January 11, 2021. https://www.npr.org/2020/06/29/885096130/federal-court-in-wisconsin-upholds-voting-restrictions-favored-by-republicans.

[10] Luzer, Daniel. "Alabama Closing Many DMV Offices in Majority Black Counties." Governing. Last modified October 2, 2015. Accessed January 11, 2021. https://www.governing.com/archive/alabama-demands-voter-id--then-closes-drivers-license-offices-In-clack-counties.html.

[11] Davis, Elliott. "U.S. Election Integrity Compares Poorly to Other Democracies." U.S. News and World Report. Last modified October 7, 2020. Accessed January 11, 2021. https://www.usnews.com/news/best-countries/articles/2020-10-07/us-elections-compare-poorly-to-other-democracies-research-shows.

Bibliography

"A History of Voter Suppression." National Low Income Housing Coalition. Last modified October 31, 2020. Accessed January 11, 2021. https://nlihc.org/resource/history-voter-suppression.

Davis, Elliott. "U.S. Election Integrity Compares Poorly to Other Democracies." U.S. News and World Report. Last modified October 7, 2020. Accessed January 11, 2021. https://www.usnews.com/news/best-countries/articles/2020-10-07/us-elections-compare-poorly-to-other-democracies-research-shows.

Feis, Aaron. "Two Capitol cops suspended in riot probe, congressman says." New York Post. Last modified January 11, 2021. Accessed January 11, 2021. https://nypost.com/2021/01/11/two-capitol-cops-suspended-one-law-enforcement-member-arrested-pol/.

HUSTED, OHIO SECRETARY OF STATE v. A. PHILIP RANDOLPH INSTITUTE, 584 S. Ct. (June 11, 2018).

Lopez, German. "How the Voting Rights Act transformed black voting rights in the South, in one chart." Vox. Last modified March 6, 2015. Accessed January 11, 2021. https://www.vox.com/2015/3/6/8163229/voting-rights-act-1965.

Luzer, Daniel. "Alabama Closing Many DMV Offices in Majority Black Counties." Governing. Last modified October 2, 2015. Accessed January 11, 2021. https://www.governing.com/archive/alabama-demands-voter-id--then-closes-drivers-license-offices-In-clack-counties.html.

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