National: Presumed guilty: Ex-felons face barriers to voting rights | MSNBC

When the votes are tallied in Virginia’s race for governor on Tuesday, over 300,000 citizens will be missing from the voting rolls – including 20% of the state’s black population. The reason is not low turnout or voter ID, but a growing and often invisible barrier to voting that is upending elections around the country. Over 5 million Americans are barred from voting because they have criminal records, according to a report this year from the Sentencing Project. The crackdown on ballot access is so intense, a majority of states actually bar former convicts from voting even after they are released from prison.  If voting rights were restored to those former inmates, about 4.3 million more Americans would be able to vote. That is over three times margin of victory in the last House midterm elections.

Montana: Judges send Indian voting case back to Montana | Ravalli Republic

A voting rights lawsuit involving three American Indian tribes will go back to a federal court in Montana after an appellate panel declined to intervene. The plaintiffs from the Crow, Northern Cheyenne and Fort Belknap tribes say three counties should set up satellite voting offices to make up for the long distances they must drive to reach courthouses for early voting or late registration. After a now-retired judge declined to intervene before the 2012 election, the 16 Indian plaintiffs appealed. But a three-judge appeals panel wrote in a Wednesday opinion that the emergency injunction request by the Indians is now moot. They sent the case back to U.S. District Court in Montana for a decision on future elections.

Falkland Islands: General election an important choice for a time of change | MercoPress

The constitution of the Falkland Islands requires that a general election be held every four years to choose the eleven members of the Islands’ Legislative Assembly or lower house of government. The next General Election is due to be held on November 7th this year. Once elected, members will choose three of their number to become members of the Executive Council, which is the upper house of the Falkland Islands. While the Executive Council is presided over by a Governor appointed by the British Government and includes a small number of other members such as the Attorney General of the Falkland Islands, the three elected members of the Executive Council drawn from among the elected members of the Legislative Assembly are the only members to have voting rights. Out of a resident population estimated at 2,931 on the occasion of the last census in April of 2012, there are nearly 2,000 people eligible to vote by reason of their being over the age of 18 and possessing the necessary status.

Kentucky: Opposition to Felon Voting Rights Thawing, Kentucky Lawmaker Says | WFPL

Saying Kentucky state senators have been the historical roadblock, Democrat Gerald Neal of Louisville has pre-filed a bill to restore voting rights to certain former felons. Movement on the proposal comes weeks after U.S. Sen. Rand Paul, R-Ky., spoke out in favor of restoring felons’ voting rights at the state and federal levels, which many observers argue is an indication the GOP may be changing its view on the issue. For the past six years, the Democratic-led state House has passed similar proposals by wide, bipartisan margins to give convicted felons their rights back. All of those measures have died in the Republican-controlled Senate and often without a hearing. Neal says senators in the Republican caucus are beginning to come around and putting the bill in his chamber first is a better strategy given its history.

Montana: DOJ Declares Indian Vote Denial ‘Completely Incorrect’ | ICTMN.com

“May it please the court, Erin Flynn on behalf of the United States.” So began the Justice Department’s presentation in a landmark Native voting-rights lawsuit. The Ninth Circuit Court of Appeals, sitting in Portland, Oregon, heard oral arguments in the suit,Wandering Medicine v. McCulloch,on October 10. The appeals court’s decision, upcoming in the next few months, will turn on whether a Montana district judge misread Section 2 of the Voting Rights Act when he denied requests for satellite registration and early-voting offices on isolated Montana reservations. The local magistrate reasoned that Indians have been elected to office in the state, so Indian voters’ lack of equal rights—which he readily acknowledged—was immaterial. “The district judge held that as long as Indians get to vote at all, what’s the problem,” said plaintiffs’ attorney Steven Sandven, of Sioux Falls. “The law needs to be clarified.”

Wisconsin: Voting wars coming to Wisconsin | Washington Post

As if Wisconsin needed another debate to divide its citizens, the voting wars are coming to Madison. The state Senate last week passed four measures, three almost exclusively on party-line votes, to make minor changes to election day procedures. One measure would require two poll workers of opposite party affiliation to oversee securing ballot containers. Another would require any job that needed two or more poll workers to be performed by members of different parties. A third bill would mandate damaged or problem ballots be marked in a uniform manner. And a bill that is likely to cause the most outrage among Democrats would require election workers to record the type of documents newly registered voters use as proof of residence. That bill passed the Senate on a straight 18-15 party-line vote. The new rules are relatively minor tweaks to the state’s election rules, a far cry from a law requiring voters to show identification at the polling place the Republican House and Senate passed back in 2011. That law was blocked by a state judge, a decision that’s being appealed in federal court. The fact that even the smallest changes to state law come down to party-line votes highlights the partisan divide in a state that’s accustomed to compromise. Democrats see the Republican-initiated changes as the first step toward more regulations that will make it harder for their voters to cast a ballot.

Editorials: Florida voter purge a bad idea | Miami Herald

Here we go again. Gov. Rick Scott and Secretary of State Ken Detzner want to conduct another purge of Florida voter rolls. Their attempt to purge the rolls of noncitizens in 2012 was a complete flop. Florida’s Division of Elections, which Mr. Detzner oversees, botched the purge, which was conducted in advance of a presidential election, raising justified questions about the timing, and with little evidence that a clean-up was needed. It alienated voters and angered most election supervisors who oversee voter rolls in the state’s 67 counties. Using Florida driver license information, state officials initially came up with 182,000 potential noncitizens who were registered to vote. That number was whittled down to 2,600 and then to a measly 198, with county elections supervisors finding many errors. Snagged as noncitizens were U.S. military veterans, including one who fought at the Battle of the Bulge. State officials finally backed down and suspended the effort.

North Carolina: In skirmish in national voting-rights wars, student once thrown off ballot wins race | Washington Post

Being thrown off the ballot was the best thing that ever happened to Montravias King. The national coverage that rained down on the Elizabeth City State University student when a local elections board in North Carolina rejected his initial City Council bid surely helped him break out from the field of candidates. He got the chance to plead his case, and his views, before millions, reaching many more people than a meager campaign budget could ever allow. This week, according to preliminary results, the university senior was the top vote-getter and will get to represent the ward where his school is located. Was turnout affected by the actions of the board in an increasingly partisan state atmosphere where restrictive voting laws have drawn legal action from many groups, including the U.S. Justice Department? King, who never stopped thinking local, didn’t take any chances, knocking on 365 doors for votes, he said in the News & Record. He said that in addition to his fellow students, he had gotten a “great and amazing” reception from older voters. That he had also discussed the issue of voter suppression with MSNBC host Rachel Maddow, who went to North Carolina for the story, was an unexpected extra.

Editorials: North Carolina local elections find students fired up to fight rights rollbacks | Facing South

If the local elections that took place across North Carolina this week are any indication, the Republican effort to roll back voting rights in the state and enact other regressive policies have inspired students at historically black schools to stand up, soldier forth, and fight back at the ballot box. After Elizabeth City State University student Montravias King declared his intention to run for a local city council seat earlier this year, he faced a legal challenge from Pasquotank County GOP chair Richard “Pete” Gilbert. Gilbert claimed King should be disqualified because he was registered to vote at his college dormitory, arguing that it is only a temporary residence. Gilbert had previously challenged registrations of students at the historically black school for the same reason but not of students at the nearby largely white Christian college. The Pasquotank County Board of Elections sided with Gilbert and struck King from the ballot. But with the help of attorneys with the Southern Coalition for Social Justice, King appealed the local board’s decision to the state elections board, which last month unanimously upheld his constitutional right to run for office.

Mississippi: Groups say Mississippi needs lessons on fair voting laws | The Advertiser

Voting rights advocates say there’s a message for Mississippi in lawsuits the Justice Department has filed over the last two months to block voting-law changes in Texas and North Carolina. The suits claim the changes, including new voter ID laws, would suppress the minority vote. Mississippi is moving ahead with its own voter ID law, and voting rights advocates say the recent legal actions by the Justice Department should put the state on notice that it may be next. “The battle in North Carolina, Texas, they’re not just state fights,” said William Barber, president of the North Carolina NAACP. “They are state battles that have national implications. If you don’t stop it here, it has the potential like a virus to spread across the country.”

Australia: Tony Abbott bluntly rejects calls for residency rights for New Zealand migrants after meeting with PM John Key | ABC

Prime Minister Tony Abbott has bluntly rejected calls to give around 200,000 New Zealanders living in Australia greater access to citizenship, taxpayer benefits and other government support. Since 2001, New Zealanders moving to Australia have not been automatically considered permanent residents and must instead apply for a temporary visa, such as the Special Category Visa (SCV). Holders of temporary visas, such as the SCV, do not have access to welfare, voting rights and student loans, while permanent residents do.

Editorials: Voter suppression? – States move to tighten rules | Columbia Daily Tribune

The expected is happening. After the U.S. Supreme Court outlawed a key provision in the Voting Rights Act, a number of GOP-led states quickly moved to restrict access to the polls by passing or strengthening voter identification laws. Critics say the new rules disproportionately affect minorities, including the elderly. Supporters say they are protecting the integrity of elections against fraud. On paper, both are legitimate goals, but as staked out in this debate, both can’t coexist legally. It’s a job for federal courts. If I had judicial authority, based on what I know now the decision would be easy. The new rules in Texas and North Carolina and Florida are an unconstitutional interference with voting rights.

Japan: Court: Barring prisoners from voting violates Constitution | The Asahi Shimbun

The Osaka High Court on Sept. 27 ruled that denying prisoners the right to vote violates the Constitution, an unprecedented decision hailed by human rights lawyers but blasted by the Justice Ministry. A senior ministry official said the ruling was “totally unexpected” and could create problems in the judicial system. “If the law is revised to give voting rights to prisoners, who make up the majority of people in justice institutions, it would have considerable ramifications,” the official said. “We will have to hold talks with the internal affairs ministry.” Presiding Judge Hiroshi Kojima dismissed the government’s argument that prisoners lack a law-abiding spirit and cannot be expected to exercise their right to vote in a fair manner. The judge also noted that prisoners are allowed to vote in a national referendum, which is required in procedures to revise the Constitution.

Ireland: ‘Emigrants don’t need Dáil votes. They’ve got Facebook!’ | Irish Post

The Irish abroad do not need a voice in Leinster House because they have the likes of Facebook and Twitter, a minister from the Irish Government has claimed. Speaking exclusively to The Irish Post, Junior Finance Minister Brian Hayes said all Irish passport holders should be given a say in Ireland’s Presidential elections. But the growth of social media has eliminated their need for a political voice at home, he added. The Fine Gael TD’s comments come amidst revelations that Irish emigration is at an all-time high. Almost 90,000 people left Ireland in the 12 months to April this year, with one person emigrating every four minutes and 60 starting a new life in Britain every day. Fianna Fáil’s spokesperson for the Irish overseas previously told The Irish Post that the Government must respond to the mass exodus by giving the Irish abroad a voice in the Oireachtas rather than just a “tokenistic” vote for its President.

Editorials: Voting access must extend to all Americans | The Missoulian

The ability to vote is one of the most basic rights every American citizen can claim as their own. It is one, through years of protest and activism, which has become not only a hallmark of democracy, but of equality. The right to vote, and the ability to do so, represents the most basic element of a government in which the people have the ability to govern themselves. Yet today, across the country, and especially here in Montana, American Indians are being denied their rights to basic voting practices which are common amongst other populations. Currently, there is a suit that has been appealed to the Ninth Circuit Court of Appeals, which is fighting for the installation of satellite voting centers on every reservation in Montana. Representatives of Northern Cheyenne, Crow, and Gros Ventre and Assiniboine tribes filed the suit in 2012 when the state denied a request to install satellite voting offices on several reservations. Satellite voting offices allow for early voting, a practice that increases voter access and enables people who are unable to get to the polls on election day to still cast a vote.

Florida: State wants to scrub voter rolls again | Highlands Today

Ken Detzner wants to counties to purge voter rolls again. After last year’s fuss, however, Florida’s secretary of state is touring the state to explain Project Integrity. Penny Ogg will listen, but Highlands County’s elections supervisor isn’t convinced another state-led purge is necessary. “Through transparency and the statutory due-process protection afforded to every voter, we can ensure the continued integrity of our voter rolls while protecting the voting rights of eligible voters from those who may cast an illegal vote,” Detzner said in a press release last week. “I am going to the roundtable discussion with Secretary Detzner in Orlando on Oct. 7,” Ogg said. “After that meeting, we hope to have better information regarding this issue since we, as supervisors, have not been given details of how they plan to roll out this new phase.” More meetings are scheduled in Panama City, Jacksonville, Sarasota and Fort Lauderdale. Nearly all the 67 elections supervisors scrapped last year’s purge – requested by Gov. Rick Scott – after they discovered the majority of 2,600 voters flagged by Detzner’s office were eligible. Most were minorities or had Hispanic-sounding surnames. Last year’s Florida crossmatched dataset included the names of naturalized citizens and even some who were born in the U.S.

Kentucky: Senate Republican Leader Open to Giving Felon Voting Rights a Second Look | WFPL

A day after U.S. Sen. Rand Paul called on Republican lawmakers in the Kentucky General Assembly to give restoration of felon voting rights a second look, a prominent GOP state senator says the caucus might be open to the idea. Speaking at the Plymouth Community Renewal Center earlier this week, Paul said U.S. drug laws disproportionately effect racial minorities. One of the consequences, Paul said, is voter disenfranchisement for African-Americans. The senator told west Louisville residents he would lobby leaders in the Republican-controlled state Senate to seek a compromise on House Bill 70. The bill would automatically give certain felons their rights back and passed the state House in a bipartisan 72-25 vote. But it stalled in the state Senate this year.

South Dakota: Native voting rights group seeks county’s help | The Argus Leader

Minnehaha County commissioners Tuesday received a second visit from a voting rights activist who wants the commission to censure the county’s insurance cooperative. Bret Healy, consultant for the Four Directions voting rights group, reiterated a request that the county formally express its disapproval of the South Dakota Public Assurance Alliance seeking to recover costs from plaintiffs in a federal voting rights lawsuit against the state and Shannon and Fall River counties. U.S. District Judge Karen Schreier dismissed the suit after the state and counties agreed to use federal Help America Vote Act funds to set up satellite voting on the Oglala Sioux Tribe’s Pine Ridge reservation.

North Carolina: One victory, one defeat for student voting rights in North Carolina | MSNBC

In what’s been described as a victory for student voting rights, the North Carolina Board of Elections ruled Tuesday that an Elizabeth City State University student can run for office using his school address, despite challenges from Republicans. The Pasquotank County Republican Party chair had challenged Montravias King‘s candidacy for city council on the grounds that his on-campus address did not prove permanent residency. Republicans on the local board of elections upheld that challenge, disqualifying King from running for office. On Tuesday, the State Board of Elections reversed that decision.

South Dakota: No deal on voting rights lawsuit fees | The Argus Leader

An inability to agree to the wording of a joint news release has stalled negotiations between the Four Directions voting rights advocacy group and the South Dakota Public Assurance Alliance, the insurance cooperative that provides liability coverage to local government entities in the state. Four Directions executive director O.J. Semans now plans a return to the court of public opinion to try to persuade the SDPAA to stop trying to recover $6,300 in court costs from 25 mostly low-income plaintiffs from the Oglala Sioux Tribe who filed a federal lawsuit against the state and Shannon and Fall River counties to get early voting provisions established on the tribe’s Pine Ridge Reservation. But SDPAA executive director Judy Payne said she thinks while an initial agreement could not be reached, talks between the insurance cooperative and Four Directions are ongoing. “We’re still waiting to hear from their attorney,” she said Thursday. SDPAA lawyer Sara Frankenstein and Four Directions lawyer Steven Sandven are the principals exchanging positions on a joint press statement, “as it should be,” Payne said.

Editorials: In a victory for voting rights, NC elections board OKs student bid for local office | Facing South

The Republican-controlled North Carolina State Board of Elections voted unanimously Tuesday to overturn a county election board’s ruling barring a student at a historically black college from running for local office because he’s registered to vote on campus. “Justice has prevailed,” Montravias King said after the board’s vote. Back in July, the senior at Elizabeth City State University filed to run for a local council seat. Local Republican Party official Richard “Pete” Gilbert challenged King’s candidacy last month, arguing that because his dorm address was only temporary he did not meet the residency requirements to run for city office. Voting rights advocates pointed out that North Carolina’s residency requirements for running for office and voting are the same. “This is a case about whether college students across the state can be denied the right to vote,” said King’s attorney, Clare Barnett with the Durham, N.C.-based Southern Coalition for Social Justice.

National: Struggle for Women’s Rights and Civil Rights Linked | Huffington Post

The nation commemorates two anniversaries this month. Women’s Equality Day on August 26 is federal recognition of the day in 1920 when the 19th Amendment became law and women were granted the right to vote. Around the country, many communities are planning activities. Two days later, Americans will stop and remember the 50th anniversary of the 1963 March on Washington for Jobs and Freedom, where Dr. Martin Luther King Jr. gave his stirring “I Have a Dream” speech at the Lincoln Memorial. A march in Washington and a rally on the National Mall are planned for August 28. It is especially fitting that these two important dates are paired because the fight for racial equality is intertwined in the fight for women’s equality in our country’s history. Ultimately, what history teaches is that there is no racial equality and no gender equality without equality for all. That’s why Vision 2020, a national coalition of organizations and individuals united in the commitment to achieve women’s economic and social equality, works to build bridges across gender and racial divides.

National: Democrats push back on voting rights | The Washington Post

After crying foul over Republican efforts to modify election laws in key states, Democrats are launching their own wide-ranging push to change the way Americans vote, kicking off the latest battles in a fight over voting rights that’s as old as the republic itself. Last week, operatives tied to the Democratic Legislative Campaign Committee launched what they call a 50-state initiative to promote voting reforms that would make it easier to cast a ballot. The effort is being run by American Values First, an outside group organized under Section 501(c)(4) of the Internal Revenue Code and run by Michael Sargeant, the DLCC’s executive director. Democrats will push legislation similar to a Colorado measure signed into law earlier this year that requires all elections to be conducted by mail. Legislators in at least seven other states will propose bills that would tweak election laws in other ways. In some states controlled by Democrats, the measures have a good chance to pass. In other states with divided control or that operate under Republican control, Democrats plan to use the measures as political cudgels, painting the GOP as opposed to basic voting rights.

Editorials: What Does the Constitution Actually Say About Voting Rights? | Garrett Epps/The Atlantic

Since the Supreme Court’s 5-4 decision in Shelby County v. Holder in June, conservative governments in the South and elsewhere have raced to introduce new voting restrictions. Most prominent in the attacks is the comprehensive vote-restriction law passed by the Republican majority in the North Carolina legislature. The law cuts back early voting, restricts private groups from conducting voter-registration drives, eliminates election-day voter registration, and imposes the strictest voter ID rules in the country. There is evidence that Republican legislatures elsewhere will follow North Carolina’s lead. Neither the American people nor the federal courts would tolerate restrictions of this sort if they were imposed on free speech, free assembly, freedom of religion, or freedom to petition government for redress of grievances. For that matter, many Southern states–and probably a majority of the Supreme Court–would reject far less onerous restrictions on the right to “keep and bear arms.” Yet each of those rights is mentioned only once in the Constitution. The “right to vote” is mentioned five times–and yet the Court has brushed it aside as a privilege that states may observe at their convenience. Even an overwhelming majority of Congress–which is given the power to enforce the right in no fewer than four different places in the Constitution–cannot protect this right more strongly than the Court feels appropriate. What would happen if we took the Constitution’s text on this matter seriously?

North Carolina: County elections boards in North Carolina challenging college student voting patterns | NewsObserver.com

Montravias King is an Elizabeth City State University senior who has been voting in Pasquotank County since he started school there four years ago. The civic-minded student government leader has voted early in city, county, state and national elections in the Pasquotank County seat in northeastern North Carolina, always using his campus dorm address. Now King wants to run for City Council in his college town and his campaign has drawn the attention of such national media figures as MSNBC’s Rachel Maddow, a vocal critic of the sweeping North Carolina elections revisions signed into law last week. Pete Gilbert, the Pasquotank Republican Party chairman, has tried to put a halt to King’s candidacy in a campaign that could test the scope of the state’s elections law changes. As voting site changes are proposed for other college campuses, the Eastern North Carolina incident also could test the extent to actions that voting rights advocates have described as a GOP-controlled effort to weaken turnout among young voters more likely to vote against them.

Texas: Dallas County could take on Texas over voter ID law | The Dallas Morning News

Dallas County commissioners on Tuesday could join a federal challenge to a controversial state law that requires voters to show photo identification. Commissioners are expected to vote on whether to hire a law firm to join a federal lawsuit at Tuesday’s regular meeting. The move would pit county leaders against state officials. U.S. Attorney General Eric Holder said last month he is also taking aim at Texas legislators’ voting laws. Battles over voter identification laws have raged across the country in recent years. Supporters are typically Republicans. They say the laws prevent ineligible voters from casting ballots. Opponents are typically Democrats. They say such laws are designed to keep poor residents and minorities from casting ballots by adding financial and bureaucratic hurdles to voting. Dallas County Judge Clay Jenkins and District Attorney Craig Watkins, both Democrats, said in a joint statement Monday that the law “could disenfranchise many registered voters.”

National: Obamacare: Can You Register to Vote at State Health Care Insurance Exchanges? | Stateline

Two of the fiercest political disputes between Washington and the states could soon come together in legal fights that involve tying the new federal health care overhaul to voter registration. Every state is preparing to open a health insurance exchange by Oct. 1. Whether these new agencies will offer voter registration as well as health care information is emerging as a potential fault line that could further divide states from one another and from Washington. The Obama administration and voting rights advocates say there’s no question the agencies must offer voter registration under federal law. But Republicans in Congress and in some states are pushing back, and even some election law experts aren’t so sure the question has an easy answer. So far, just three states have officially said they’ll link the exchanges and voter registration. But whether the rest will – or will be required to under federal law – is an open question that will likely lead to court battles and at least a temporary patchwork approach nationwide. “I don’t expect it to go evenly and don’t expect it to go well, initially,” said R. Doug Lewis, head of the National Association of Election Officials. “There’s not universal agreement about what can be done here, as you can imagine.”

Kansas: Proof-of-citizenship law targeting fraud puts voting rights in limbo for 15,000 residents | The Washington Post

A few weeks after moving to suburban Kansas City from the Seattle area, Aaron Belenky went online to register to vote but ended up joining thousands of other Kansas residents whose voting rights are in legal limbo because of the state’s new proof-of-citizenship rule. Starting this year, new voters aren’t legally registered in Kansas until they’ve presented a birth certificate, passport or other document demonstrating U.S. citizenship. Kansas is among a handful of GOP-dominated states enacting such a rule to keep noncitizens from voting, but the most visible result so far is a growing pool of nearly 15,000 residents who’ve filled out registration forms but can’t legally cast ballots yet. Critics of the law point out that the number of people whose registrations aren’t yet validated — and who are blocked from voting — far outpaces the few hundred ballots over the last 15 years that Kansas officials have reported as potentially tainted by irregularities. Preventing election fraud was often cited as the reason for enacting the law.

Kansas: ACLU notifies Kobach of intention to file voting rights lawsuit | LJWorld.com

The American Civil Liberties Union today notified Kansas Secretary of State Kris Kobach that it will file a lawsuit in 90 days if the state doesn’t address the issue of approximately 14,000 voter registration applications that are in limbo. “Kansans are simply trying to exercise their constitutional right to vote,” said Dale Ho, director of the ACLU’s Voting Rights Project. “This is the most fundamental freedom we have as Americans, yet Secretary of State Kobach is blocking thousands upon thousands of Kansans from their rightful participation in the political process. This is un-American, unconstitutional and must end immediately.” The dispute is over thousands of voter registration applications in Kansas since January when a new state law took effect that requires new registrations to include proof of U.S. citizenship with a document such as a birth certificate or passport.

CLU letter to Kobach ( .PDF )

Editorials: The Republican Push to Make it Harder to Vote | Linda Killian/The Atlantic

Within 20 minutes of the Supreme Court’s decision overturning a portion of the Voting Rights Act, the attorney general of Texas tweeted a message signaling that strict voter-ID laws would go into effect there immediately. “I’ll fight Obama’s effort to control our elections,” Greg Abbott, who just announced he’s running for governor of Texas, tweeted June 25, the day the 5-4 decision in Shelby County v. Holder was released. Unless the law can be successfully challenged in court, Texas residents will now have to show a state- or federal-issued form of photo identification to vote. The list of acceptable forms includes a concealed-handgun license but not a state university student ID. The omission suggests it is not voter fraud but voters unfriendly to the GOP that Abbott and other Texas Republicans are trying to thwart. Other states — like Mississippi and Arkansas – that have GOP-controlled legislatures and a history of racial discrimination, and whose election laws have been supervised by the Department of Justice since the VRA’s passage in 1965, have also wasted no time moving forward with new voting restrictions in the wake of the Shelby County decision.