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In fact, in 2006 Congress reauthorized the Voting Rights Act on the basis that "vestiges of discrimination in voting continue to exist as demonstrated by second generation barriers constructed to prevent minority voters from fully participating in the electoral process".
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But these second-generation barriers cut "down the right to vote as certainly as denial of access to the ballot".
"And I think what we're dealing with now, as she said, are kind of second-generation barriers to voting rights.
She said the focus of the Voting Rights Act had properly changed from "first-generation barriers to ballot access" to "second-generation barriers" like racial gerrymandering and laws requiring at-large voting in places with a sizable black minority.
"Getting back to Justice Ginsburg, she talked about what we faced in 1965 being kind of the first-generation barriers," Holder said.
Some older-generation barriers blocked the view of Mexico, but the Border Patrol found those frustrating because agents could not see the migrants amassing on the other side.
She noted that Congress had based its 2006 reauthorization on a fifteen-thousand-page legislative record documenting both outright vote denial and "second-generation barriers constructed to prevent minority voters from fully participating in the electoral process".
As for Section 4, Ginsburg wrote that "the record for the 2006 reauthorization makes abundantly clear [that] second-generation barriers to minority voting rights have emerged in the covered jurisdictions as attempted substitutes for the first-generation barriers that originally triggered preclearance in those jurisdictions".
"Obviously the VRA still plays a huge role in protecting voters, but it remains to be seen how the Voting Rights Act will protect against second-generation barriers," Ebenstein said.
A book that has crossed that three-generation barrier has a good chance at permanence.
Many women from my generation have a tremendous generational barrier that encompasses not just age but also culture: I and other women like me didn't grow up here, and it shows.
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Since I tried Ludwig back in 2017, I have been constantly using it in both editing and translation. Ever since, I suggest it to my translators at ProSciEditing.

Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com