134 Harv. L. Rev. 1 Volume 134, November 10 2020 –  The Supreme Court Term 2019 – The Degradation of American Democracy — And the Court – Foreword by Michael J. Klarman. “On June 25, 2013, the Supreme Court invalidated the geographic coverage formula of the 1965 Voting Rights Act, effectively abrogating the preclearance requirement in section 5 of the Act. Under that provision, most states of the former Confederacy had been required to “preclear” changes to their voting laws and practices with a federal court in Washington, D.C., or with the Department of Justice to ensure those changes did not deny or abridge the right to vote on the basis of race. Announcing that “history did not end in 1965” and that “[o]ur country has changed,” Chief Justice Roberts, writing for the conservative majority of the Court, ruled that the geographic coverage formula contained in section 4(b) and used to identify jurisdictions subject to section 5 was outdated and could no longer be constitutionally justified. Texas Republicans apparently did not receive Chief Justice Roberts’s memo announcing how much “our country has changed.” Just hours after the decision, Texas implemented a law, enacted two years earlier but blocked by preclearance, that required government-issued photo identification to vote. The list of approved forms of identification included those more commonly possessed by Republican-leaning voters, such as a concealed handgun permit, but not those more commonly possessed by Democratic-leaning voters, such as college identification cards. Hundreds of thousands of registered Texas voters did not possess valid forms of voter identification under the law, including disproportionate numbers of African Americans and Latino Americans. Moreover, nearly a third of the state’s counties, including some with large populations of people of color, did not have motor vehicle offices, which provide driver’s licenses, the most common form of voter identification…”