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Some have argued that Section 2 was implicitly repealed by the Fifteenth Amendment, but the Supreme Court has acknowledged the provisions of Section 2 in recent times.
For example, in Richardson v. Ramirez, the Court cited Section 2 as justification for the states disenfranchising felons.
In his dissent, Justice Marshall explained the history of the Section 2 in relation to the Post-Civil War Reconstruction era:

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