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William & Mary Law Review Online

Abstract

This article critiques the Supreme Court's decision in Allen v. Milligan for relying solely on Thornburg v. Gingles and overlooking Chisom v. Roemer, a key precedent interpreting § 2 of the Voting Rights Act. Chisom established that vote dilution claims must be tied to unequal access to the political process, not just electoral outcomes. By ignoring this linkage, the Court risks turning § 2 into a vehicle for race-based electoral entitlements. The author argues that reaffirming Chisom is essential to preserving the statute’s process-focused intent and analytical clarity.

This abstract was written using generative artificial intelligence.

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