In Shelby County v. Holder, decided this June, the United States Supreme Court struck down Section 4 of the 2006 Fannie Lou Hamer, Rosa Parks, and Coretta Scott King Voting Rights Act Reauthorization and Amendments Act (“2006 VRA”). Section 4 of the VRA provides a coverage formula for nine states as well as counties in six additional states that must seek “preclearance” for any changes to their electoral practices under Section 5 of the VRA from either the federal Department of Justice or a three-judge Federal District Court in Washington DC.

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