ORIGINAL 1984 PHOTO MARTIN LUTHER KING Sr AFRICAN AMERICAN BY PULITZER WINNER

Description: A scarce 8x10 inch photo of Mr Martin Luther king Sr BY FAMED PHOTOGRAPHER AND PULITZER PRIZE WINNER JIMMY TAFOYA Mr. Tafoya was part of the staff that received a Pulitzer Prize for coverage of the 1967 riot in Detroit Martin Luther King was born Michael King in Stockbridge, Georgia, the son of Delia (née Linsey; 1875–1924) and James Albert King (1864–1933).[1] Martin Luther King was a member of the Baptist Church and decided to become a preacher after being inspired by ministers who were prepared to stand up for racial equality. He was boarding with Reverend A.D. Williams, then pastor of the Ebenezer Baptist Church. After King started courting Williams' daughter, Alberta, her family encouraged him to finish his education and to become a preacher. King completed his high school education at Bryant Preparatory School, and began to preach in several black churches in Atlanta. In 1926, King started his ministerial degree at the Morehouse School of Religion. On Thanksgiving Day in 1926, after eight years of courtship, he married Alberta in the Ebenezer Church.[2] The couple had three children in four years: a daughter, Willie Christine King (born 1927), Martin Luther King Jr. (born Michael King Jr., 1929–1968), and a second son, Alfred Daniel Williams King (1930–1969). King became leader of the Ebenezer Baptist Church in March 1931 after the death of Williams.[3] With the country in the midst of the Great Depression, church finances were struggling, but King organized membership and fundraising drives that restored these to health. By 1934, King had become a widely respected leader of the local church. That year, he also changed his name (and that of his eldest son) from Michael King to Martin Luther King after a period of gradual transition on his own part.[4] He was inspired during a trip to Germany for that year's meeting of the Baptist World Alliance (BWA). While visiting sites associated with reformation leader Martin Luther, attendees also witnessed the rise of Nazism. Whilst the BWA conference issued a resolution condemning antisemitism, the senior King gained deepened appreciation for the power of Luther's protest.[5] King was the pastor of the Ebenezer Baptist Church for four decades, wielding great influence in the black community and earning some degree of respect from the white community. He also broadcast on WAEC, a religious radio station in Atlanta. He became a local leader of the Civil Rights Movement, serving on the executive committee of the NAACP chapter in Atlanta[6] and the Civic and Political League as an officer.[7] He encouraged his son to become active in the movement. In his 1950 essay An Autobiography of Religious Development, King Jr. wrote that his father was a major influence on his entering the ministry. He said, "I guess the influence of my father also had a great deal to do with my going in the ministry. This is not to say that he ever spoke to me in terms of being a minister, but that my admiration for him was the great moving factor; He set forth a noble example that I didn't mind following." King Jr. often recounted that his father frequently sent him to work in the fields. He said that in this way he would gain a healthier respect for his forefathers. In his autobiography, King Jr. remembered his father leaving a shoe shop because he and his son were asked to change seats. He said, "This was the first time I had seen Dad so furious. That experience revealed to me at a very early age that my father had not adjusted to the system, and he played a great part in shaping my conscience. I still remember walking down the street beside him as he muttered, 'I don't care how long I have to live with this system, I will never accept it.'"[8] Another story related by King Jr. was that once the car his father was driving was stopped by a police officer, and the officer addressed the senior King as "boy". King pointed to his son, saying, "This is a boy, I'm a man; until you call me one, I will not listen to you." King Jr. became an associate pastor at Ebenezer in 1948, and his father wrote a letter of recommendation for him to attend the Crozer Theological Seminary in Chester, Pennsylvania. King Sr. also made arrangement for King Jr. to work with J. Pius Barbour, a family friend who pastored at Calvary Baptist Church in Chester.[9] Despite theological differences, father and son would later serve together as joint pastors at the church. King was a major figure in the Civil Rights Movement in Georgia, where he rose to become the head of the NAACP in Atlanta and the Civic and Political League. He led the fight for equal teachers' salaries in Atlanta. He also played an instrumental role in ending Jim Crow laws in the state. King had refused to ride on Atlanta's bus system since the 1920s after a vicious attack on black passengers with no action against those responsible. King stressed the need for an educated, politically active black ministry. In October 1960, when King Jr. was arrested at a peaceful sit-in in Atlanta, Robert F. Kennedy, brother and aide to the Democratic presidential nominee John F. Kennedy, telephoned the judge and helped secure his release. Although King Sr. had previously opposed John Kennedy because he was a Catholic, he expressed his appreciation for these calls and switched his support to Kennedy. Until this time, King Sr. had been a lifelong registered Republican, and had endorsed Republican Richard Nixon before switching to endorse Kennedy.[10] King Jr. soon became a popular civil rights activist. Taking inspiration from Mahatma Gandhi of India, he led nonviolent protests in order to win greater rights for African Americans. King Jr. was shot and killed in 1968 by James Earl Ray. King Sr.'s youngest son, Alfred Daniel Williams King, died under mysterious circumstances that authorities labeled an accidental drowning on July 21, 1969, nine days before his 39th birthday. In 1969, King was one of several members of the Morehouse College board of trustees held hostage on the campus by a group of students demanding reform in the school's curriculum and governance. One of the students was Samuel L. Jackson, who was suspended for his actions. Jackson subsequently became an actor and Academy Award nominee.[11] King played a notable role in the nomination of Jimmy Carter as the Democratic candidate for president in the 1976 election. After Carter's success in the Iowa caucus, the New Hampshire primary and the Florida primary, some liberal Democrats were worried about his success and began an "ABC" ("Anyone But Carter") movement to try to head off his nomination. King pointed to Carter's leadership in ending the era of segregation in Georgia and helping to repeal laws restricting voting which especially disenfranchised African Americans. With King's support, Carter continued to build a coalition of black and white voters and win the nomination. King delivered the invocation at the 1976 and 1980 Democratic National Conventions. Murder of wifeKing Sr.'s wife and King Jr.'s mother, Alberta, was murdered by Marcus Wayne Chenault on Sunday, June 30, 1974, at the Ebenezer Baptist Church during Sunday services. Chenault was a 23-year-old black man from Ohio who stood up and yelled, "You are serving a false god", and fired his gun while Alberta was playing "The Lord's Prayer" on the church organ.[12] Upon capture, the assassin disclosed that his intended target was Martin Luther King Sr., who was elsewhere that Sunday. After failing to see King Sr., he instead targeted Alberta King and Rev. Edward Boykin.[13] Chenault stated that he was driven to murder after concluding that "black ministers were a menace to black people" and that "all Christians are his enemies".[14] Alberta Christine Williams King (September 13, 1904 – June 30, 1974) was an American civil rights organizer best known as the mother of Martin Luther King Jr., and as the wife of Martin Luther King Sr. She played a significant role in the affairs of the Ebenezer Baptist Church. She was shot and killed in the church by 23-year-old Black Hebrew Israelite Marcus Wayne Chenault six years after the assassination of her eldest son Martin Luther King Jr.[1] Life and career Martin Luther King Jr. (left), Henry Elkins (center), and Alberta Williams King (right) at Ebenezer in 1962Alberta Christine Williams was born on September 13, 1904.[2] Her parents were Reverend Adam Daniel Williams, at the time preacher of the Ebenezer Baptist Church in Atlanta, Georgia, and Jennie Celeste (Parks) Williams.[3] Alberta Williams graduated from high school at the Spelman Seminary, and earned a teaching certificate at the Hampton Normal and Industrial Institute (now Hampton University) in 1924.[4] Williams met Martin L. King (then known as Michael King), whose sister Woodie was boarding with her parents, shortly before she left for Hampton. After graduating, she announced her engagement to King at the Ebenezer Baptist Church.[4] She taught for a short time before their Thanksgiving Day 1926 wedding, but she had to quit because the local school board prohibited married women from teaching.[4] After their wedding the newly married couple moved into an upstairs bedroom at the Williams's family home, which is where all three of their children were subsequently born.[5] The King family lived in the home until King's mother's death from a heart attack in 1941, when Martin Jr. turned 12 years old.[6] In 1980 the home was designated for preservation as part of the Martin Luther King Jr. National Historical Park.[6] The house the family subsequently moved to was located nearby (it has since been torn down).[6] The King's first child, daughter Willie Christine King, was born on September 11, 1927.[7] Michael King Jr. followed on January 15, 1929, then Alfred Daniel Williams King I, named after his grandfather, on July 30, 1930.[8] About this time, Michael King changed his name to Martin Luther King Sr.[9] Alberta King worked hard to instill self-respect into her children. In an essay he wrote at Crozer Seminary, Martin Luther King Jr., who was always close to her, wrote that she "was behind the scenes setting forth those motherly cares, the lack of which leaves a missing link in life."[4] During this period King continued her studies at Morris Brown College, receiving a BA in 1938.[10] King founded the Ebenezer choir and served as church organist from 1932 to 1972.[4] Her work as organist and as director at Ebenezer is considered to have deeply contributed to the respect her son had for music.[11] She served as choir director for nearly 25 years, leaving for only a brief period in the early 1960s to accompany her son and assist him with his work.[12] She returned to the position in 1963 and continued in the role until "retiring" in 1972.[12] In addition to the choir, Alberta would also serve as the organizer and president of the Ebenezer Women's Committee from 1950 to 1962. By the end of this period, Martin Luther King Sr. and Jr. were joint pastors of the church. Outside of her work at Ebenezer, King was the organist for the Women’s Auxiliary of the National Baptist Convention from 1950 to 1962.[4] She was also active in the YWCA, the National Association for the Advancement of Colored People (NAACP), and the Women’s International League for Peace and Freedom.[4] Family tragedies, 1968–1974Martin Luther King Jr. was assassinated on April 4, 1968, while standing on the balcony of the Lorraine Motel in Memphis. King was in Memphis to lead a march in support of the local sanitation workers' union. He was pronounced dead one hour later. Mrs. King, a source of strength following her son's assassination, faced fresh tragedy the next year when her younger son and last-born child, Alfred Daniel Williams King, who had become the assistant pastor at the Ebenezer Baptist Church, drowned in his pool. AssassinationAlberta King was shot and killed on June 30, 1974, aged 69, by Marcus Wayne Chenault, a 23-year-old Black man from Ohio who had adopted the theology of the Black Hebrew Israelites.[13] Chenault's mentor, Hananiah Israel of Cincinnati, castigated Black civil rights activists and Black church leaders as being evil and deceptive, but claimed in interviews not to have advocated violence.[14] Chenault did not draw any such distinction, and first decided to assassinate Rev. Jesse Jackson in Chicago, but canceled the plan at the last minute. Two weeks later he set out for Atlanta, where he shot Alberta King with two handguns as she sat at the organ of the Ebenezer Baptist Church. Chenault said that he shot King because "all Christians are my enemies," and claimed that he had decided that Black ministers were a menace to Black people. He said his original target had been Martin Luther King Sr., but he had decided to shoot King's wife instead because she was near him. He also killed one of the church's deacons, Edward Boykin, in the attack and wounded retired schoolteacher Jimmie Mitchell in the neck.[12] King and Boykin were rushed to the nearby Grady Memorial Hospital.[1] Officials announced King was "barely alive" when she arrived at the hospital. Boykin was pronounced dead on arrival.[1] King died shortly afterward from a gunshot wound to the right of her head.[1] Alberta King was interred at the South-View Cemetery in Atlanta.[15] Martin Luther King Sr. died of a heart attack on November 11, 1984,[16] and was interred next to her.[15] Assassin's convictionChenault was convicted of first-degree murder and sentenced to death. The sentence was upheld on appeal. He was later resentenced to life in prison, partially as a result of the King family's opposition to the death penalty.[17] On August 3, 1995, he suffered a stroke, and was taken to a hospital. On August 19, he died aged 44 from complications from his stroke.[18][19] The 70-year-old mother of the late Rev Martin Luther King, the civil rights leader who was assassinated six years ago, was herself shot and killed today as she played the organ for morning service in the Ebenezer Baptist Church in the centre of Atlanta, Georgia. Her assailant, a young black man, who eye-witnesses said "went berserk," and who was later reported to have said that "all Christians" were his enemies, was held by members of the church choir after he had wounded two other members of the congregation, one of them fatally. Aware of the potential consequences of this latest tragedy, the Mayor of Atlanta, Mr Maynard Jackson, issued a statement beseeching the community to remain calm. Mr Jackson, elected last year as the first black mayor of a major southern city, had returned abruptly to Atlanta from a West Coast conference last Wednesday after ominous civil disturbances had erupted in the streets following the police shooting of a young black man who had violated his parole. The mood in the city had been calming after the tense and uneasy week when this morning's tragic shootings took place. Atlanta said later that a 21-year-old black man, Marcus Wayne Chenault, of Dayton, Ohio, had been charged with two counts of murder, one of assault, and one of carrying a concealed weapon. According to witnesses Mrs Alberta King, whose husband, the Rev Martin Luther King Snr, is pastor of the church on Auburn Avenue, was playing the organ for the Lord's Prayer near the start of the service when the attack began. A young black man jumped and screamed: "You must stop this! I am tired of all this! I'm taking over this morning." With that he drew two pistols and for the next 90 seconds fired wildly and continuously, hitting Mrs King, another elderly woman parishioner, and a 69-year-old church deacon, Mr Edward Boykin. 'Delirious'While members of the congregation dived beneath the pews, a few men from the choir jumped on the gunman, who was shouting: " I’m going to kill everyone in here - they did it to me in the war." Mrs King's grandson Derek, who said he helped to subdue the gunman as he tried to reload a pistol, added: "He was delirious. He appeared to be in a fever. He said over and over, 'The war did this to me. It's the war.'" Mrs King was taken to the nearby Grady Memorial Hospital, where officials said she was "barely alive" on arrival. She died shortly afterwards from a gunshot wound to the right of her head. Mr Boykin was pronounced dead on arrival. The attack on Mrs King took place less than 100 yards from where her famous son, killed in 1968 at the age of 39, is buried. Martin Luther King Jr. (born Michael King Jr.; January 15, 1929 – April 4, 1968) was an American Baptist minister and activist who was one of the most prominent leaders in the civil rights movement from 1955 until his assassination in 1968. A Black church leader and a son of early civil rights activist and minister Martin Luther King Sr., King advanced civil rights for people of color in the United States through nonviolence and civil disobedience. Inspired by his Christian beliefs and the nonviolent activism of Mahatma Gandhi, he led targeted, nonviolent resistance against Jim Crow laws and other forms of discrimination in the United States. King participated in and led marches for the right to vote, desegregation, labor rights, and other civil rights.[1] He oversaw the 1955 Montgomery bus boycott and later became the first president of the Southern Christian Leadership Conference (SCLC). As president of the SCLC, he led the unsuccessful Albany Movement in Albany, Georgia, and helped organize some of the nonviolent 1963 protests in Birmingham, Alabama. King was one of the leaders of the 1963 March on Washington, where he delivered his "I Have a Dream" speech on the steps of the Lincoln Memorial. The civil rights movement achieved pivotal legislative gains in the Civil Rights Act of 1964, Voting Rights Act of 1965, and the Fair Housing Act of 1968. The SCLC put into practice the tactics of nonviolent protest with some success by strategically choosing the methods and places in which protests were carried out. There were several dramatic standoffs with segregationist authorities, who frequently responded violently.[2] King was jailed several times. Federal Bureau of Investigation (FBI) director J. Edgar Hoover considered King a radical and made him an object of the FBI's COINTELPRO from 1963 forward. FBI agents investigated him for possible communist ties, spied on his personal life, and secretly recorded him. In 1964, the FBI mailed King a threatening anonymous letter, which he interpreted as an attempt to make him commit suicide.[3] On October 14, 1964, King won the Nobel Peace Prize for combating racial inequality through nonviolent resistance. In 1965, he helped organize two of the three Selma to Montgomery marches. In his final years, he expanded his focus to include opposition towards poverty, capitalism, and the Vietnam War. In 1968, King was planning a national occupation of Washington, D.C., to be called the Poor People's Campaign, when he was assassinated on April 4 in Memphis, Tennessee. His death was followed by national mourning, as well as anger leading to riots in many U.S. cities. King was posthumously awarded the Presidential Medal of Freedom in 1977 and the Congressional Gold Medal in 2003. Martin Luther King Jr. Day was established as a holiday in cities and states throughout the United States beginning in 1971; the federal holiday was first observed in 1986. Hundreds of streets in the U.S. have been renamed in his honor, and King County in Washington was rededicated for him. The Martin Luther King Jr. Memorial on the National Mall in Washington, D.C., was dedicated in 2011. Early life and educationBirthKing was born Michael King Jr. on January 15, 1929, in Atlanta, Georgia, the second of three children to Michael King and Alberta King (née Williams).[4][5][6] King had an older sister, Christine King Farris, and a younger brother, Alfred Daniel "A.D." King.[7] Alberta's father, Adam Daniel Williams,[8] was a minister in rural Georgia, moved to Atlanta in 1893,[6] and became pastor of the Ebenezer Baptist Church in the following year.[9] Williams married Jennie Celeste Parks.[6] King, Sr. was born to sharecroppers, James Albert and Delia King of Stockbridge, Georgia,[5][6] and was of African-Irish descent.[10][11][12] In his adolescent years, King Sr. left his parents' farm and walked to Atlanta where he attained a high school education,[13][14][15] and enrolled in Morehouse College to study for entry to the ministry.[15] King Sr. and Alberta began dating in 1920, and married on November 25, 1926.[16][17] Until Jennie's death in 1941, they lived together on the second floor of Alberta's parents' two-story Victorian house, where King was born.[18][16][17][19] Shortly after marrying Alberta, King Sr. became assistant pastor of the Ebenezer church.[17] Senior pastor Williams died in the spring of 1931[17] and that fall, King Sr. took the role, where he would in time raise the attendance from six hundred to several thousand.[17][6] In 1934, the church sent King Sr. on a multinational trip, including to Berlin for the meeting of the Congress of the Baptist World Alliance (BWA).[20] He also visited sites in Germany associated with the Reformation leader, Martin Luther.[20] While there, King Sr. and the BWA delegates witnessed the rise of Nazism.[20] In reaction, the BWA issued a resolution stating, "This Congress deplores and condemns as a violation of the law of God the Heavenly Father, all racial animosity, and every form of oppression or unfair discrimination toward the Jews, toward coloured people, or toward subject races in any part of the world."[21] On returning home in August 1934, King Sr. changed his name to Martin Luther King and his five-year-old son's name to Martin Luther King Jr.[20][22][16][a] Early childhood King's childhood home in Atlanta, GeorgiaAt his childhood home, King and his two siblings would read aloud the Bible as instructed by their father.[24] After dinners there, King's grandmother Jennie, whom he affectionately referred to as "Mama", would tell lively stories from the Bible to her grandchildren.[24] King's father would regularly use whippings to discipline his children.[25] At times, King Sr. would also have his children whip each other.[25] King's father later remarked, "[King] was the most peculiar child whenever you whipped him. He'd stand there, and the tears would run down, and he'd never cry."[26] Once when King witnessed his brother A.D. emotionally upset his sister Christine, he took a telephone and knocked out A.D. with it.[25][27] When he and his brother were playing at their home, A.D. slid from a banister and hit into their grandmother, Jennie, causing her to fall unresponsive.[28][27] King, believing her dead, blamed himself and attempted suicide by jumping from a second-story window.[29][27] Upon hearing that his grandmother was alive, King rose and left the ground where he had fallen.[29] King became friends with a white boy whose father owned a business across the street from his family's home.[30] In September 1935, when the boys were about six years old, they started school.[30][31] King had to attend a school for black children, Yonge Street Elementary School,[30][32] while his close playmate went to a separate school for white children only.[30][32] Soon afterwards, the parents of the white boy stopped allowing King to play with their son, stating to him "we are white, and you are colored".[30][33] When King relayed the happenings to his parents, they had a long discussion with him about the history of slavery and racism in America.[30][34] Upon learning of the hatred, violence and oppression that black people had faced in the U.S., King would later state that he was "determined to hate every white person".[30] His parents instructed him that it was his Christian duty to love everyone.[34] King witnessed his father stand up against segregation and various forms of discrimination.[35] Once, when stopped by a police officer who referred to King Sr. as "boy", King's father responded sharply that King was a boy but he was a man.[35] When King's father took him into a shoe store in downtown Atlanta, the clerk told them they needed to sit in the back.[36] King's father refused, stating "we'll either buy shoes sitting here or we won't buy any shoes at all", before taking King and leaving the store.[14] He told King afterward, "I don't care how long I have to live with this system, I will never accept it."[14] In 1936, King's father led hundreds of African Americans in a civil rights march to the city hall in Atlanta, to protest voting rights discrimination.[25] King later remarked that King Sr. was "a real father" to him.[37] King memorized and sang hymns, and stated verses from the Bible, by the time he was five years old.[29] Over the next year, he began to go to church events with his mother and sing hymns while she played piano.[29] His favorite hymn to sing was "I Want to Be More and More Like Jesus"; he moved attendees with his singing.[29] King later became a member of the junior choir in his church.[38] King enjoyed opera, and played the piano.[39] As he grew up, King garnered a large vocabulary from reading dictionaries and consistently used his expanding lexicon.[27] He got into physical altercations with boys in his neighborhood, but oftentimes used his knowledge of words to stymie fights.[27][39] King showed a lack of interest in grammar and spelling, a trait that he carried throughout his life.[39] In 1939, King sang as a member of his church choir in slave costume, for the all-white audience at the Atlanta premiere of the film Gone with the Wind.[40][41] In September 1940, at the age of 11, King was enrolled at the Atlanta University Laboratory School for the seventh grade.[42][43] While there, King took violin and piano lessons, and showed keen interest in his history and English classes.[42] On May 18, 1941, when King had sneaked away from studying at home to watch a parade, King was informed that something had happened to his maternal grandmother.[37] Upon returning home, he found out that she had suffered a heart attack and died while being transported to a hospital.[19] He took the death very hard and believed that his deception of going to see the parade may have been responsible for God taking her.[19] King jumped out of a second-story window at his home, but again survived an attempt to kill himself.[19][26][27] His father instructed him in his bedroom that King should not blame himself for her death, and that she had been called home to God as part of God's plan that could not be changed.[19][44] King struggled with this, and could not fully believe that his parents knew where his grandmother had gone.[19] Shortly thereafter, King's father decided to move the family to a two-story brick home on a hill that overlooked downtown Atlanta.[19] Adolescence The high school that King attended was named after African-American educator Booker T. Washington.In his adolescent years, he initially felt resentment against whites due to the "racial humiliation" that he, his family, and his neighbors often had to endure in the segregated South.[45] In 1942, when King was 13 years old, he became the youngest assistant manager of a newspaper delivery station for the Atlanta Journal.[46] That year, King skipped the ninth grade and was enrolled in Booker T. Washington High School, where he maintained a B-plus average.[44][47] The high school was the only one in the city for African-American students.[17] It had been formed after local black leaders, including King's grandfather (Williams), urged the city government of Atlanta to create it.[17] While King was brought up in a Baptist home, King grew skeptical of some of Christianity's claims as he entered adolescence.[48] He began to question the literalist teachings preached at his father's church.[49] At the age of 13, he denied the bodily resurrection of Jesus during Sunday school.[50][49] King said that he found himself unable to identify with the emotional displays and gestures from congregants frequent at his church, and doubted if he would ever attain personal satisfaction from religion.[51][49] He later stated of this point in his life, "doubts began to spring forth unrelentingly."[52][50][49] In high school, King became known for his public-speaking ability, with a voice that had grown into an orotund baritone.[53][47] He proceeded to join the school's debate team.[53][47] King continued to be most drawn to history and English,[47] and chose English and sociology to be his main subjects while at the school.[54] King maintained an abundant vocabulary.[47] But, he relied on his sister, Christine, to help him with his spelling, while King assisted her with math.[47] They studied in this manner routinely until Christine's graduation from high school.[47] King also developed an interest in fashion, commonly adorning himself in well polished patent leather shoes and tweed suits, which gained him the nickname "Tweed" or "Tweedie" among his friends.[55][56][57][58] He further grew a liking for flirting with girls and dancing.[57][56][59] His brother A. D. later remarked, "He kept flitting from chick to chick, and I decided I couldn't keep up with him. Especially since he was crazy about dances, and just about the best jitterbug in town."[56] On April 13, 1944, in his junior year, King gave his first public speech during an oratorical contest, sponsored by the Improved Benevolent and Protective Order of Elks of the World in Dublin, Georgia.[60][56][61][62] In his speech he stated, "black America still wears chains. The finest negro is at the mercy of the meanest white man. Even winners of our highest honors face the class color bar."[63][60] King was selected as the winner of the contest.[60][56] On the ride home to Atlanta by bus, he and his teacher were ordered by the driver to stand so that white passengers could sit down.[56][64] The driver of the bus called King a "black son-of-a-bitch".[56] King initially refused but complied after his teacher told him that he would be breaking the law if he did not follow the directions of the driver.[64] As all the seats were occupied, he and his teacher were forced to stand on the rest of the drive back to Atlanta.[56] Later King wrote of the incident, saying "That night will never leave my memory. It was the angriest I have ever been in my life."[64] Morehouse CollegeDuring King's junior year in high school, Morehouse College—an all-male historically black college that King's father and maternal grandfather had attended[65][66]—began accepting high school juniors who passed the school's entrance examination.[56][67][64] As World War II was underway many black college students had been enlisted in the war, decreasing the numbers of students at Morehouse College.[56][67] So, the university aimed to increase their student numbers by allowing juniors to apply.[56][67][64] In 1944, at the age of 15, King passed the entrance examination and was enrolled at the university for the school season that autumn.[b][56][67][65][68] In the summer before King started his freshman year at Morehouse, he boarded a train with his friend—Emmett "Weasel" Proctor—and a group of other Morehouse College students to work in Simsbury, Connecticut, at the tobacco farm of Cullman Brothers Tobacco (a cigar business).[69][70] This was King's first trip outside of the segregated south into the integrated north.[71][72] In a June 1944 letter to his father King wrote about the differences that struck him between the two parts of the country, "On our way here we saw some things I had never anticipated to see. After we passed Washington there was no discrimination at all. The white people here are very nice. We go to any place we want to and sit any where we want to."[71] The students worked at the farm to be able to provide for their educational costs at Morehouse College, as the farm had partnered with the college to allot their salaries towards the university's tuition, housing, and other fees.[69][70] On weekdays King and the other students worked in the fields, picking tobacco from 7:00am till at least 5:00pm, enduring temperatures above 100 °F, to earn roughly USD$4 per day.[70][71] On Friday evenings, King and the other students visited downtown Simsbury to get milkshakes and watch movies, and on Saturdays they would travel to Hartford, Connecticut, to see theatre performances, shop and eat in restaurants.[70][72] On each Sunday they would go to Hartford to attend church services, at a church filled with white congregants.[70] King wrote to his parents about the lack of segregation in Connecticut, relaying how he was amazed they could go to "one of the finest restaurants in Hartford" and that "Negroes and whites go to the same church".[70][73][71] He played freshman football there. The summer before his last year at Morehouse, in 1947, the 18-year-old King chose to enter the ministry. Throughout his time in college, King studied under the mentorship of its president, Baptist minister Benjamin Mays, who he would later credit with being his "spiritual mentor".[74] King had concluded that the church offered the most assuring way to answer "an inner urge to serve humanity". His "inner urge" had begun developing, and he made peace with the Baptist Church, as he believed he would be a "rational" minister with sermons that were "a respectful force for ideas, even social protest."[75] King graduated from Morehouse with a Bachelor of Arts (BA) in sociology in 1948, aged nineteen.[76] Religious education, ministry, marriage and familyCrozer Theological SeminaryA large facade of a buildingKing received a Bachelor of Divinity degree at Crozer Theological Seminary (pictured in 2009).King enrolled in Crozer Theological Seminary in Upland, Pennsylvania.[77][78] King's father fully supported his decision to continue his education and made arrangements for King to work with prominent Crozer alum, J. Pius Barbour, a family friend who pastored at Calvary Baptist Church in nearby Chester, Pennsylvania.[79] King became known as one of the "Sons of Calvary", an honor he shared with William Augustus Jones Jr. and Samuel D. Proctor who both went on to become well-known preachers in the black church.[80] While attending Crozer, King was joined by Walter McCall, a former classmate at Morehouse.[81] At Crozer, King was elected president of the student body.[82] The African-American students of Crozer for the most part conducted their social activity on Edwards Street. King became fond of the street because a classmate had an aunt who prepared collard greens for them, which they both relished.[83] King once reproved another student for keeping beer in his room, saying they had shared responsibility as African Americans to bear "the burdens of the Negro race". For a time, he was interested in Walter Rauschenbusch's "social gospel".[82] In his third year at Crozer, King became romantically involved with the white daughter of an immigrant German woman who worked as a cook in the cafeteria. The woman had been involved with a professor prior to her relationship with King. King planned to marry her, but friends advised against it, saying that an interracial marriage would provoke animosity from both blacks and whites, potentially damaging his chances of ever pastoring a church in the South. King tearfully told a friend that he could not endure his mother's pain over the marriage and broke the relationship off six months later. He continued to have lingering feelings toward the woman he left; one friend was quoted as saying, "He never recovered."[82] King graduated with a Bachelor of Divinity (B.Div.) degree in 1951.[77] He applied to the University of Edinburgh to do his doctorate in the School of Divinity. An offer was made by Edinburgh but he chose Boston instead.[84] Boston UniversitySee also: Martin Luther King Jr. authorship issuesIn 1951, King began doctoral studies in systematic theology at Boston University.[85] While pursuing doctoral studies, King worked as an assistant minister at Boston's historic Twelfth Baptist Church with William Hunter Hester. Hester was an old friend of King's father and was an important influence on King.[86] In Boston, King befriended a small cadre of local ministers his age, and sometimes guest pastored at their churches, including Michael Haynes, associate pastor at Twelfth Baptist Church in Roxbury (and younger brother of jazz drummer Roy Haynes). The young men often held bull sessions in their various apartments, discussing theology, sermon style, and social issues. King attended philosophy classes at Harvard University as an audit student in 1952 and 1953.[87] At the age of 25 in 1954, King was called as pastor of the Dexter Avenue Baptist Church in Montgomery, Alabama.[88] King received his PhD degree on June 5, 1955, with a dissertation (initially supervised by Edgar S. Brightman and, upon the latter's death, by Lotan Harold DeWolf) titled A Comparison of the Conceptions of God in the Thinking of Paul Tillich and Henry Nelson Wieman.[89][85] An academic inquiry in October 1991 concluded that portions of his doctoral dissertation had been plagiarized and he had acted improperly. However, "[d]espite its finding, the committee said that 'no thought should be given to the revocation of Dr. King's doctoral degree,' an action that the panel said would serve no purpose."[90][85][91] The committee found that the dissertation still "makes an intelligent contribution to scholarship." A letter is now attached to the copy of King's dissertation held in the university library, noting that numerous passages were included without the appropriate quotations and citations of sources.[92] Significant debate exists on how to interpret King's plagiarism.[93] Marriage and family Martin Luther King Jr. with his wife, Coretta Scott King, and daughter, Yolanda Denise King, in 1956While studying at Boston University, he asked a friend from Atlanta named Mary Powell, who was a student at the New England Conservatory of Music, if she knew any nice Southern girls. Powell asked fellow student Coretta Scott if she was interested in meeting a Southern friend studying divinity. Scott was not interested in dating preachers but eventually agreed to allow Martin to telephone her based on Powell's description and vouching. On their first phone call, King told Scott "I am like Napoleon at Waterloo before your charms," to which she replied, "You haven't even met me." They went out for dates in his green Chevy. After the second date, King was certain Scott possessed the qualities he sought in a wife. She had been an activist at Antioch as an undergraduate student. King married Coretta Scott on June 18, 1953, on the lawn of her parents' house in her hometown of Heiberger, Alabama.[94] They became the parents of four children: Yolanda King (1955–2007), Martin Luther King III (b. 1957), Dexter Scott King (b. 1961), and Bernice King (b. 1963).[95] During their marriage, King limited Coretta's role in the civil rights movement, expecting her to be a housewife and mother.[96] In December 1959, after being based in Montgomery for five years, King announced his return to Atlanta at the request of the SCLC.[97] In Atlanta, King served until his death as co-pastor with his father at the Ebenezer Baptist Church, and helped expand the Civil Rights Movement across the South. Activism and organizational leadershipMontgomery bus boycott, 1955Main articles: Montgomery bus boycott and Jim Crow laws § Public arena King (left) with civil rights activist Rosa Parks (right) in 1955The Dexter Avenue Baptist Church, where King was called to be a minister in 1954, was influential in the Montgomery, Alabama, African-American community. As the church's pastor, he became known for his oratorical preaching in Montgomery and the surrounding region.[98] In March 1955, Claudette Colvin—a fifteen-year-old black schoolgirl in Montgomery—refused to give up her bus seat to a white man in violation of Jim Crow laws, local laws in the Southern United States that enforced racial segregation. King was on the committee from the Birmingham African-American community that looked into the case; E. D. Nixon and Clifford Durr decided to wait for a better case to pursue because the incident involved a minor.[99] Nine months later on December 1, 1955, a similar incident occurred when Rosa Parks was arrested for refusing to give up her seat on a city bus.[100] The two incidents led to the Montgomery bus boycott, which was urged and planned by Nixon and led by King.[101] King was in his twenties, and had just taken up his clerical role. The other ministers asked him to take a leadership role simply because his relative newness to community leadership made it easier for him to speak out. King was hesitant about taking the role but decided to do so if no one else wanted it.[102] The boycott lasted for 385 days,[103] and the situation became so tense that King's house was bombed.[104] King was arrested for traveling 30 mph in a 25 mph zone[105] and jailed during this campaign, which overnight drew the attention of national media, and greatly increased King's public stature. The controversy ended when the United States District Court issued a ruling in Browder v. Gayle that prohibited racial segregation on all Montgomery public buses.[106] Blacks resumed riding the buses again, and were able to sit in the front with full legal authorization.[1][102] King's role in the bus boycott transformed him into a national figure and the best-known spokesman of the civil rights movement.[107] King first rose to prominence in the civil rights movement while minister of Dexter Avenue Baptist Church in Montgomery, Alabama.Southern Christian Leadership ConferenceIn 1957, King, Ralph Abernathy, Fred Shuttlesworth, Joseph Lowery, and other civil rights activists founded the Southern Christian Leadership Conference (SCLC). The group was created to harness the moral authority and organizing power of black churches to conduct nonviolent protests in the service of civil rights reform. The group was inspired by the crusades of evangelist Billy Graham, who befriended King,[108] as well as the national organizing of the group In Friendship, founded by King allies Stanley Levison and Ella Baker.[109] King led the SCLC until his death.[110] The SCLC's 1957 Prayer Pilgrimage for Freedom was the first time King addressed a national audience.[111] Other civil rights leaders involved in the SCLC with King included: James Bevel, Allen Johnson, Curtis W. Harris, Walter E. Fauntroy, C. T. Vivian, Andrew Young, The Freedom Singers, Cleveland Robinson, Randolph Blackwell, Annie Bell Robinson Devine, Charles Kenzie Steele, Alfred Daniel Williams King, Benjamin Hooks, Aaron Henry and Bayard Rustin.[112] The Gandhi SocietyHarry Wachtel joined King's legal advisor Clarence B. Jones in defending four ministers of the SCLC in the libel case New York Times Co. v. Sullivan; the case was litigated about the newspaper advertisement "Heed Their Rising Voices". Wachtel founded a tax-exempt fund to cover the suit's expenses and assist the nonviolent civil rights movement through a more effective means of fundraising. This organization was named the "Gandhi Society for Human Rights". King served as honorary president for the group. He was displeased with the pace that President Kennedy was using to address the issue of segregation. In 1962, King and the Gandhi Society produced a document that called on the President to follow in the footsteps of Abraham Lincoln and issue an executive order to deliver a blow for civil rights as a kind of Second Emancipation Proclamation. Kennedy did not execute the order.[113] The FBI was under written directive from Attorney General Robert F. Kennedy when it began tapping King's telephone line in the fall of 1963.[114] Kennedy was concerned that public allegations of communists in the SCLC would derail the administration's civil rights initiatives. He warned King to discontinue these associations and later felt compelled to issue the written directive that authorized the FBI to wiretap King and other SCLC leaders.[115] FBI Director J. Edgar Hoover feared the civil rights movement and investigated the allegations of communist infiltration. When no evidence emerged to support this, the FBI used the incidental details caught on tape over the next five years, as part of its COINTELPRO program, in attempts to force King out of his leadership position [3] King believed that organized, nonviolent protest against the system of southern segregation known as Jim Crow laws would lead to extensive media coverage of the struggle for black equality and voting rights. Journalistic accounts and televised footage of the daily deprivation and indignities suffered by southern blacks, and of segregationist violence and harassment of civil rights workers and marchers, produced a wave of sympathetic public opinion that convinced the majority of Americans that the civil rights movement was the most important issue in American politics in the early 1960s.[116][117] King organized and led marches for blacks' right to vote, desegregation, labor rights, and other basic civil rights.[1] Most of these rights were successfully enacted into the law of the United States with the passage of the Civil Rights Act of 1964 and the 1965 Voting Rights Act.[118][119] The SCLC put into practice the tactics of nonviolent protest with great success by strategically choosing the methods and places in which protests were carried out. There were often dramatic stand-offs with segregationist authorities, who sometimes turned violent.[2] Survived knife attack, 1958On September 20, 1958, King was signing copies of his book Stride Toward Freedom in Blumstein's department store in Harlem[120] when he narrowly escaped death. Izola Curry—a mentally ill black woman who thought that King was conspiring against her with communists—stabbed him in the chest with a letter opener, which nearly impinged on the aorta. King received first aid by police officers Al Howard and Philip Romano.[121] King underwent emergency surgery with three doctors: Aubre de Lambert Maynard, Emil Naclerio and John W. V. Cordice; he remained hospitalized for several weeks. Curry was later found mentally incompetent to stand trial.[122][123] Atlanta sit-ins, prison sentence, and the 1960 elections King led the Southern Christian Leadership Conference and later became co-pastor with his father at Ebenezer Baptist Church in Atlanta (pulpit and sanctuary pictured).Georgia governor Ernest Vandiver expressed open hostility towards King's return to his hometown in late 1959. He claimed that "wherever M. L. King Jr., has been there has followed in his wake a wave of crimes", and vowed to keep King under surveillance.[124] On May 4, 1960, several months after his return, King drove writer Lillian Smith to Emory University when police stopped them. King was cited for "driving without a license" because he had not yet been issued a Georgia license. King's Alabama license was still valid, and Georgia law did not mandate any time limit for issuing a local license.[125] King paid a fine but was unaware that his lawyer agreed to a plea deal that also included a probationary sentence. Meanwhile, the Atlanta Student Movement had been acting to desegregate businesses and public spaces in the city, organizing the Atlanta sit-ins from March 1960 onwards. In August the movement asked King to participate in a mass October sit-in, timed to highlight how 1960's Presidential election campaign had ignored civil rights. The coordinated day of action took place on October 19. King participated in a sit-in at the restaurant inside Rich's, Atlanta's largest department store, and was among the many arrested that day. The authorities released everyone over the next few days, except for King. Invoking his probationary plea deal, judge J. Oscar Mitchell sentenced King on October 25 to four months of hard labor. Before dawn the next day, King was taken from his county jail cell and transported to Georgia State Prison.[126] The arrest and harsh sentence drew nationwide attention. Many feared for King's safety, as he started a prison sentence with people convicted of violent crimes, many of them White and hostile to his activism.[127] Both Presidential candidates were asked to weigh in, at a time when both parties were courting the support of Southern Whites and their political leadership including Governor Vandiver. Nixon, with whom King had a closer relationship before, declined to make a statement despite a personal visit from Jackie Robinson requesting his intervention. Nixon's opponent John F. Kennedy called the governor (a Democrat) directly, enlisted his brother Robert to exert more pressure on state authorities, and also, at the personal request of Sargent Shriver, made a phone call to King's wife to express his sympathy and offer his help. The pressure from Kennedy and others proved effective, and King was released two days later. King's father decided to openly endorse Kennedy's candidacy for the November 8 election which he narrowly won.[128] After the October 19 sit-ins and following unrest, a 30-day truce was declared in Atlanta for desegregation negotiations. However, the negotiations failed and sit-ins and boycotts resumed in full swing for several months. On March 7, 1961, a group of Black elders including King notified student leaders that a deal had been reached: the city's lunch counters would desegregate in fall 1961, in conjunction with the court-mandated desegregation of schools.[129][130] Many students were disappointed at the compromise. In a large meeting on March 10 at Warren Memorial Methodist Church, the audience was hostile and frustrated towards the elders and the compromise. King then gave an impassioned speech calling participants to resist the "cancerous disease of disunity", and helping to calm tensions.[131] Albany Movement, 1961Main article: Albany MovementThe Albany Movement was a desegregation coalition formed in Albany, Georgia, in November 1961. In December, King and the SCLC became involved. The movement mobilized thousands of citizens for a broad-front nonviolent attack on every aspect of segregation within the city and attracted nationwide attention. When King first visited on December 15, 1961, he "had planned to stay a day or so and return home after giving counsel."[132] The following day he was swept up in a mass arrest of peaceful demonstrators, and he declined bail until the city made concessions. According to King, "that agreement was dishonored and violated by the city" after he left town.[132] King returned in July 1962 and was given the option of forty-five days in jail or a $178 fine (equivalent to $1,600 in 2021); he chose jail. Three days into his sentence, Police Chief Laurie Pritchett discreetly arranged for King's fine to be paid and ordered his release. "We had witnessed persons being kicked off lunch counter stools ... ejected from churches ... and thrown into jail ... But for the first time, we witnessed being kicked out of jail."[133] It was later acknowledged by the King Center that Billy Graham was the one who bailed King out of jail during this time.[134] After nearly a year of intense activism with few tangible results, the movement began to deteriorate. King requested a halt to all demonstrations and a "Day of Penance" to promote nonviolence and maintain the moral high ground. Divisions within the black community and the canny, low-key response by local government defeated efforts.[135] Though the Albany effort proved a key lesson in tactics for King and the national civil rights movement,[136] the national media was highly critical of King's role in the defeat, and the SCLC's lack of results contributed to a growing gulf between the organization and the more radical SNCC. After Albany, King sought to choose engagements for the SCLC in which he could control the circumstances, rather than entering into pre-existing situations.[137] Vice President Lyndon B. Johnson and Attorney General Robert F. Kennedy with King, Benjamin Mays, and other civil rights leaders, June 22, 1963Birmingham campaign, 1963Main article: Birmingham campaign King was arrested in 1963 for protesting the treatment of blacks in Birmingham.[138]In April 1963, the SCLC began a campaign against racial segregation and economic injustice in Birmingham, Alabama. The campaign used nonviolent but intentionally confrontational tactics, developed in part by Wyatt Tee Walker. Black people in Birmingham, organizing with the SCLC, occupied public spaces with marches and sit-ins, openly violating laws that they considered unjust. King's intent was to provoke mass arrests and "create a situation so crisis-packed that it will inevitably open the door to negotiation."[139] The campaign's early volunteers did not succeed in shutting down the city, or in drawing media attention to the police's actions. Over the concerns of an uncertain King, SCLC strategist James Bevel changed the course of the campaign by recruiting children and young adults to join in the demonstrations.[140] Newsweek called this strategy a Children's Crusade.[141][142] During the protests, the Birmingham Police Department, led by Eugene "Bull" Connor, used high-pressure water jets and police dogs against protesters, including children. Footage of the police response was broadcast on national television news and dominated the nation's attention, shocking many white Americans and consolidating black Americans behind the movement.[143] Not all of the demonstrators were peaceful, despite the avowed intentions of the SCLC. In some cases, bystanders attacked the police, who responded with force. King and the SCLC were criticized for putting children in harm's way. But the campaign was a success: Connor lost his job, the "Jim Crow" signs came down, and public places became more open to blacks. King's reputation improved immensely.[141] King was arrested and jailed early in the campaign—his 13th arrest[144] out of 29.[145] From his cell, he composed the now-famous "Letter from Birmingham Jail" that responds to calls on the movement to pursue legal channels for social change. The letter has been described as "one of the most important historical documents penned by a modern political prisoner".[146] King argues that the crisis of racism is too urgent, and the current system too entrenched: "We know through painful experience that freedom is never voluntarily given by the oppressor; it must be demanded by the oppressed."[147] He points out that the Boston Tea Party, a celebrated act of rebellion in the American colonies, was illegal civil disobedience, and that, conversely, "everything Adolf Hitler did in Germany was 'legal'."[147] Walter Reuther, president of the United Auto Workers, arranged for $160,000 to bail out King and his fellow protestors.[148] "I have almost reached the regrettable conclusion that the Negro's great stumbling block in his stride toward freedom is not the White Citizen's Councilor or the Ku Klux Klanner, but the white moderate, who is more devoted to "order" than to justice; who prefers a negative peace which is the absence of tension to a positive peace which is the presence of justice; who constantly says: "I agree with you in the goal you seek, but I cannot agree with your methods of direct action"; who paternalistically believes he can set the timetable for another man's freedom; who lives by a mythical concept of time and who constantly advises the Negro to wait for a "more convenient season." —Martin Luther King Jr.[147]0:11CCMartin Luther King Jr. speaking in an interview in the Netherlands, 1964March on Washington, 1963Main article: March on Washington for Jobs and Freedom Leaders of the March on Washington posing in front of the Lincoln Memorial The March on Washington for Jobs and Freedom (1963)King, representing the SCLC, was among the leaders of the "Big Six" civil rights organizations who were instrumental in the organization of the March on Washington for Jobs and Freedom, which took place on August 28, 1963. The other leaders and organizations comprising the Big Six were Roy Wilkins from the National Association for the Advancement of Colored People; Whitney Young, National Urban League; A. Philip Randolph, Brotherhood of Sleeping Car Porters; John Lewis, SNCC; and James L. Farmer Jr., of the Congress of Racial Equality.[149] Bayard Rustin's open homosexuality, support of socialism, and his former ties to the Communist Party USA caused many white and African-American leaders to demand King distance himself from Rustin,[150] which King agreed to do.[151] However, he did collaborate in the 1963 March on Washington, for which Rustin was the primary logistical and strategic organizer.[152][153] For King, this role was another which courted controversy, since he was one of the key figures who acceded to the wishes of United States President John F. Kennedy in changing the focus of the march.[154][155] Kennedy initially opposed the march outright, because he was concerned it would negatively impact the drive for passage of civil rights legislation. However, the organizers were firm that the march would proceed.[156] With the march going forward, the Kennedys decided it was important to work to ensure its success. President Kennedy was concerned the turnout would be less than 100,000. Therefore, he enlisted the aid of additional church leaders and Walter Reuther, president of the United Automobile Workers, to help mobilize demonstrators for the cause.[157] The March, a 1964 documentary film produced by the United States Information Agency. King's speech has been redacted from this video because of the copyright held by King's estate.The march originally was conceived as an event to dramatize the desperate condition of blacks in the southern U.S. and an opportunity to place organizers' concerns and grievances squarely before the seat of power in the nation's capital. Organizers intended to denounce the federal government for its failure to safeguard the civil rights and physical safety of civil rights workers and blacks. The group acquiesced to presidential pressure and influence, and the event ultimately took on a far less strident tone.[158] As a result, some civil rights activists felt it presented an inaccurate, sanitized pageant of racial harmony; Malcolm X called it the "Farce on Washington", and the Nation of Islam forbade its members from attending the march.[158][159] King gave his most famous speech, "I Have a Dream", before the Lincoln Memorial during the 1963 March on Washington for Jobs and Freedom.I Have a Dream0:3030-second sample from "I Have a Dream" speech by Martin Luther King Jr. at the March on Washington for Jobs and Freedom on August 28, 1963Problems playing this file? See media help.The march made specific demands: an end to racial segregation in public schools; meaningful civil rights legislation, including a law prohibiting racial discrimination in employment; protection of civil rights workers from police brutality; a $2 minimum wage for all workers (equivalent to $18 in 2021); and self-government for Washington, D.C., then governed by congressional committee.[160][161][162] Despite tensions, the march was a resounding success.[163] More than a quarter of a million people of diverse ethnicities attended the event, sprawling from the steps of the Lincoln Memorial onto the National Mall and around the reflecting pool. At the time, it was the largest gathering of protesters in Washington, D.C.'s history.[163] I Have a DreamMain article: I Have a DreamKing delivered a 17-minute speech, later known as "I Have a Dream". In the speech's most famous passage – in which he departed from his prepared text, possibly at the prompting of Mahalia Jackson, who shouted behind him, "Tell them about the dream!"[164][165] – King said:[166] I say to you today, my friends, so even though we face the difficulties of today and tomorrow, I still have a dream. It is a dream deeply rooted in the American dream. I have a dream that one day this nation will rise up and live out the true meaning of its creed: "We hold these truths to be self-evident: that all men are created equal." I have a dream that one day on the red hills of Georgia the sons of former slaves and the sons of former slave owners will be able to sit down together at the table of brotherhood. I have a dream that one day even the state of Mississippi, a state sweltering with the heat of injustice, sweltering with the heat of oppression, will be transformed into an oasis of freedom and justice. I have a dream that my four little children will one day live in a nation where they will not be judged by the color of their skin but by the content of their character. I have a dream today. I have a dream that one day, down in Alabama, with its vicious racists, with its governor having his lips dripping with the words of interposition and nullification; one day right there in Alabama, little black boys and black girls will be able to join hands with little white boys and white girls as sisters and brothers. I have a dream today. "I Have a Dream" came to be regarded as one of the finest speeches in the history of American oratory.[167] The March, and especially King's speech, helped put civil rights at the top of the agenda of reformers in the United States and facilitated passage of the Civil Rights Act of 1964.[168][169] The original typewritten copy of the speech, including King's handwritten notes on it, was discovered in 1984 to be in the hands of George Raveling, the first African-American basketball coach of the University of Iowa. In 1963, Raveling, then 26 years old, was standing near the podium, and immediately after the oration, impulsively asked King if he could have his copy of the speech, and he got it.[170] St. Augustine, Florida, 1964Main article: St. Augustine movementIn March 1964, King and the SCLC joined forces with Robert Hayling's then-controversial movement in St. Augustine, Florida. Hayling's group had been affiliated with the NAACP but was forced out of the organization for advocating armed self-defense alongside nonviolent tactics. However, the pacifist SCLC accepted them.[171][172] King and the SCLC worked to bring white Northern activists to St. Augustine, including a delegation of rabbis and the 72-year-old mother of the governor of Massachusetts, all of whom were arrested.[173][174] During June, the movement marched nightly through the city, "often facing counter demonstrations by the Klan, and provoking violence that garnered national media attention." Hundreds of the marchers were arrested and jailed. During this movement, the Civil Rights Act of 1964 was passed.[175] Biddeford, Maine, 1964On May 7, 1964, King spoke at Saint Francis College's "The Negro and the Quest for Identity", in Biddeford, Maine. This was a symposium that brought many civil rights leaders together such as Dorothy Day and Roy Wilkins.[176][177] King spoke about how "We must get rid of the idea of superior and inferior races," through nonviolent tactics.[178] New York City, 1964 King at a press conference in March 1964On February 6, 1964, King delivered the inaugural speech[179] of a lecture series initiated at the New School called "The American Race Crisis". In August 2013, almost 50 years later, the school discovered an audiotape with 15 minutes of a question-and-answer session that followed King's address. In these remarks, King referred to a conversation he had recently had with Jawaharlal Nehru in which he compared the sad condition of many African Americans to that of India's untouchables.[180] The original speech recording is part of a collection of audiotapes in Amherst College's Archives & Special Collections in 1989.[181] Dr. King's speech had been rebroadcast on Amherst's student-run radio station, WAMF (now WAMH). The tape was digitized in the fall of 2015 and shared with The New School Archives. In his March 18, 1964, interview by Robert Penn Warren, King compared his activism to his father's, citing his training in non-violence as a key difference. He also discusses the next phase of the civil rights movement and integration.[182] Scripto strike in Atlanta, 1964Main article: 1964–1965 Scripto strikeStarting in November 1964, King supported a labor strike led by several hundred workers at the Scripto factory in the Sweet Auburn neighborhood of Atlanta, just a few blocks from Ebenezer Baptist.[183] Many of the strikers were also congregants of his church, and the strike was supported by other civil rights leaders in the city.[183] King helped elevate the labor dispute from a local to nationally-known event and led the SCLC to organize a nationwide boycott of Scripto products.[183] However, as the strike stretched into December, King, who was wanting to focus more on a civil rights campaign in Selma, Alabama, began to negotiate in secret with Scripto's president Carl Singer and eventually brokered a deal where the SCLC would call off their boycott in exchange for the company giving the striking employees their Christmas bonuses.[183] King's involvement in the strike ended on December 24 and a contract between the company and union was signed on January 9 of the following year.[183] Selma voting rights movement and "Bloody Sunday", 1965Main article: Selma to Montgomery marches The civil rights march from Selma to Montgomery, Alabama, in 1965In December 1964, King and the SCLC joined forces with the Student Nonviolent Coordinating Committee (SNCC) in Selma, Alabama, where the SNCC had been working on voter registration for several months.[184] A local judge issued an injunction that barred any gathering of three or more people affiliated with the SNCC, SCLC, DCVL, or any of 41 named civil rights leaders. This injunction temporarily halted civil rights activity until King defied it by speaking at Brown Chapel on January 2, 1965.[185] During the 1965 march to Montgomery, Alabama, violence by state police and others against the peaceful marchers resulted in much publicity, which made racism in Alabama visible nationwide. Acting on James Bevel's call for a march from Selma to Montgomery, Bevel and other SCLC members, in partial collaboration with SNCC, attempted to organize a march to the state's capital. The first attempt to march on March 7, 1965, at which King was not present, was aborted because of mob and police violence against the demonstrators. This day has become known as Bloody Sunday and was a major turning point in the effort to gain public support for the civil rights movement. It was the clearest demonstration up to that time of the dramatic potential of King and Bevel's nonviolence strategy.[52] On March 5, King met with officials in the Johnson Administration to request an injunction against any prosecution of the demonstrators. He did not attend the march due to church duties, but he later wrote, "If I had any idea that the state troopers would use the kind of brutality they did, I would have felt compelled to give up my church duties altogether to lead the line."[186] Footage of police brutality against the protesters was broadcast extensively and aroused national public outrage.[187] King next attempted to organize a march for March 9. The SCLC petitioned for an injunction in federal court against the State of Alabama; this was denied and the judge issued an order blocking the march until after a hearing. Nonetheless, King led marchers on March 9 to the Edmund Pettus Bridge in Selma, then held a short prayer session before turning the marchers around and asking them to disperse so as not to violate the court order. The unexpected ending of this second march aroused the surprise and anger of many within the local movement.[188] Meanwhile, on March 11 King cried at the news of Johnson supporting a voting rights bill on television in Marie Foster's living room.[189] The march finally went ahead fully on March 25, 1965.[190][191] At the conclusion of the march on the steps of the state capitol, King delivered a speech that became known as "How Long, Not Long". In it, King stated that equal rights for African Americans could not be far away, "because the arc of the moral universe is long, but it bends toward justice" and "you shall reap what you sow".[c][192][193][194] Chicago open housing movement, 1966Main article: Chicago Freedom Movement King standing behind President Johnson as he signs the Civil Rights Act of 1964In 1966, after several successes in the south, King, Bevel, and others in the civil rights organizations took the movement to the North, with Chicago as their first destination. King and Ralph Abernathy, both from the middle class, moved into a building at 1550 S. Hamlin Avenue, in the slums of North Lawndale[195] on Chicago's West Side, as an educational experience and to demonstrate their support and empathy for the poor.[196] The SCLC formed a coalition with CCCO, Coordinating Council of Community Organizations, an organization founded by Albert Raby, and the combined organizations' efforts were fostered under the aegis of the Chicago Freedom Movement.[197] During that spring, several white couple/black couple tests of real estate offices uncovered racial steering: discriminatory processing of housing requests by couples who were exact matches in income, background, number of children, and other attributes.[198] Several larger marches were planned and executed: in Bogan, Belmont Cragin, Jefferson Park, Evergreen Park (a suburb southwest of Chicago), Gage Park, Marquette Park, and others.[197][199][200] President Lyndon B. Johnson meeting with King in the White House Cabinet Room in 1966King later stated and Abernathy wrote that the movement received a worse reception in Chicago than in the South. Marches, especially the one through Marquette Park on August 5, 1966, were met by thrown bottles and screaming throngs. Rioting seemed very possible.[201][202] King's beliefs militated against his staging a violent event, and he negotiated an agreement with Mayor Richard J. Daley to cancel a march in order to avoid the violence that he feared would result.[203] King was hit by a brick during one march, but continued to lead marches in the face of personal danger.[204] When King and his allies returned to the South, they left Jesse Jackson, a seminary student who had previously joined the movement in the South, in charge of their organization.[205] Jackson continued their struggle for civil rights by organizing the Operation Breadbasket movement that targeted chain stores that did not deal fairly with blacks.[206] A 1967 CIA document declassified in 2017 downplayed King's role in the "black militant situation" in Chicago, with a source stating that King "sought at least constructive, positive projects."[207] Opposition to the Vietnam WarThe black revolution is much more than a struggle for the rights of Negroes. It is forcing America to face all its interrelated flaws—racism, poverty, militarism, and materialism. It is exposing evils that are rooted deeply in the whole structure of our society. It reveals systemic rather than superficial flaws and suggests that radical reconstruction of society itself is the real issue to be faced –Martin Luther King Jr.[208]We must recognize that we can't solve our problem now until there is a radical redistribution of economic and political power... this means a revolution of values and other things. We must see now that the evils of racism, economic exploitation, and militarism are all tied together… you can't really get rid of one without getting rid of the others… the whole structure of American life must be changed. America is a hypocritical nation and [we] must put [our] own house in order. —Martin Luther King Jr.[209]See also: Opposition to United States involvement in the Vietnam WarKing was long opposed to American involvement in the Vietnam War,[210] but at first avoided the topic in public speeches in order to avoid the interference with civil rights goals that criticism of President Johnson's policies might have created.[210] At the urging of SCLC's former Director of Direct Action and now the head of the Spring Mobilization Committee to End the War in Vietnam, James Bevel, and inspired by the outspokenness of Muhammad Ali,[211] King eventually agreed to publicly oppose the war as opposition was growing among the American public.[210] During an April 4, 1967, appearance at the New York City Riverside Church—exactly one year before his death—King delivered a speech titled "Beyond Vietnam: A Time to Break Silence".[212] He spoke strongly against the U.S.'s role in the war, arguing that the U.S. was in Vietnam "to occupy it as an American colony"[213] and calling the U.S. government "the greatest purveyor of violence in the world today".[214] He connected the war with economic injustice, arguing that the country needed serious moral change: A true revolution of values will soon look uneasily on the glaring contrast of poverty and wealth. With righteous indignation, it will look across the seas and see individual capitalists of the West investing huge sums of money in Asia, Africa and South America, only to take the profits out with no concern for the social betterment of the countries, and say: "This is not just."[215] King opposed the Vietnam War because it took money and resources that could have been spent on social welfare at home. The United States Congress was spending more and more on the military and less and less on anti-poverty programs at the same time. He summed up this aspect by saying, "A nation that continues year after year to spend more money on military defense than on programs of social uplift is approaching spiritual death."[215] He stated that North Vietnam "did not begin to send in any large number of supplies or men until American forces had arrived in the tens of thousands",[216] and accused the U.S. of having killed a million Vietnamese, "mostly children".[217] King also criticized American opposition to North Vietnam's land reforms.[218] King's opposition cost him significant support among white allies, including President Johnson, Billy Graham, union leaders and powerful publishers.[219][220][221] "The press is being stacked against me", King said,[222] complaining of what he described as a double standard that applauded his nonviolence at home, but deplored it when applied "toward little brown Vietnamese children".[223] Life magazine called the speech "demagogic slander that sounded like a script for Radio Hanoi",[215] and The Washington Post declared that King had "diminished his usefulness to his cause, his country, his people."[223][224] King speaking to an anti-Vietnam war rally at the University of Minnesota in St. Paul on April 27, 1967The "Beyond Vietnam" speech reflected King's evolving political advocacy in his later years, which paralleled the teachings of the progressive Highlander Research and Education Center, with which he was affiliated.[225][226] King began to speak of the need for fundamental changes in the political and economic life of the nation, and more frequently expressed his opposition to the war and his desire to see a redistribution of resources to correct racial and economic injustice.[227][228] He guarded his language in public to avoid being linked to communism by his enemies, but in private he sometimes spoke of his support for social democracy and democratic socialism.[229][230] King stated in "Beyond Vietnam" that "true compassion is more than flinging a coin to a beggar ... it comes to see that an edifice which produces beggars needs restructuring."[231] King quoted a United States official who said that from Vietnam to Latin America, the country was "on the wrong side of a world revolution."[231] King condemned America's "alliance with the landed gentry of Latin America", and said that the U.S. should support "the shirtless and barefoot people" in the Third World rather than suppressing their attempts at revolution.[231] King's stance on Vietnam encouraged Allard K. Lowenstein, William Sloane Coffin and Norman Thomas, with the support of anti-war Democrats, to attempt to persuade King to run against President Johnson in the 1968 United States presidential election. King contemplated but ultimately decided against the proposal on the grounds that he felt uneasy with politics and considered himself better suited for his morally unambiguous role as an activist.[232] On April 15, 1967, King participated and spoke at an anti-war march from Manhattan's Central Park to the United Nations. The march was organized by the Spring Mobilization Committee to End the War in Vietnam and initiated by its chairman, James Bevel. At the U.N. King brought up issues of civil rights and the draft: I have not urged a mechanical fusion of the civil rights and peace movements. There are people who have come to see the moral imperative of equality, but who cannot yet see the moral imperative of world brotherhood. I would like to see the fervor of the civil-rights movement imbued into the peace movement to instill it with greater strength. And I believe everyone has a duty to be in both the civil-rights and peace movements. But for those who presently choose but one, I would hope they will finally come to see the moral roots common to both.[233] Seeing an opportunity to unite civil rights activists and anti-war activists,[211] Bevel convinced King to become even more active in the anti-war effort.[211] Despite his growing public opposition towards the Vietnam War, King was not fond of the hippie culture which developed from the anti-war movement.[234] In his 1967 Massey Lecture, King stated: The importance of the hippies is not in their unconventional behavior, but in the fact that hundreds of thousands of young people, in turning to a flight from reality, are expressing a profoundly discrediting view on the society they emerge from.[234] On January 13, 1968 (the day after President Johnson's State of the Union Address), King called for a large march on Washington against "one of history's most cruel and senseless wars".[235][236] We need to make clear in this political year, to congressmen on both sides of the aisle and to the president of the United States, that we will no longer tolerate, we will no longer vote for men who continue to see the killings of Vietnamese and Americans as the best way of advancing the goals of freedom and self-determination in Southeast Asia.[235][236] Correspondence with Thích Nhất HạnhThích Nhất Hạnh was an influential Vietnamese Buddhist who taught at Princeton University and Columbia University. He had written a letter to Martin Luther King Jr. in 1965 entitled: "In Search of the Enemy of Man". It was during his 1966 stay in the US that Nhất Hạnh met with King and urged him to publicly denounce the Vietnam War.[237] In 1967, King gave a famous speech at the Riverside Church in New York City, his first to publicly question the U.S. involvement in Vietnam.[238] Later that year, King nominated Nhất Hạnh for the 1967 Nobel Peace Prize. In his nomination, King said, "I do not personally know of anyone more worthy of [this prize] than this gentle monk from Vietnam. His ideas for peace, if applied, would build a monument to ecumenism, to world brotherhood, to humanity".[239] Poor People's Campaign, 1968Main article: Poor People's CampaignRows of tentsA shantytown established in Washington, D.C. to protest economic conditions as a part of the Poor People's CampaignIn 1968, King and the SCLC organized the "Poor People's Campaign" to address issues of economic justice. King traveled the country to assemble "a multiracial army of the poor" that would march on Washington to engage in nonviolent civil disobedience at the Capitol until Congress created an "economic bill of rights" for poor Americans.[240][241] The campaign was preceded by King's final book, Where Do We Go from Here: Chaos or Community? which laid out his view of how to address social issues and poverty. King quoted from Henry George and George's book, Progress and Poverty, particularly in support of a guaranteed basic income.[242][243][244] The campaign culminated in a march on Washington, D.C., demanding economic aid to the poorest communities of the United States. King and the SCLC called on the government to invest in rebuilding America's cities. He felt that Congress had shown "hostility to the poor" by spending "military funds with alacrity and generosity". He contrasted this with the situation faced by poor Americans, claiming that Congress had merely provided "poverty funds with miserliness".[241] His vision was for change that was more revolutionary than mere reform: he cited systematic flaws of "racism, poverty, militarism and materialism", and argued that "reconstruction of society itself is the real issue to be faced."[245] The Poor People's Campaign was controversial even within the civil rights movement. Rustin resigned from the march, stating that the goals of the campaign were too broad, that its demands were unrealizable, and that he thought that these campaigns would accelerate the backlash and repression on the poor and the black.[246] Assassination and aftermathMain article: Assassination of Martin Luther King Jr. The Lorraine Motel, where King was assassinated, is now the site of the National Civil Rights Museum.I've Been to the Mountaintop0:30Final 30 seconds of "I've Been to the Mountaintop" speech by Martin Luther King Jr.Problems playing this file? See media help.On March 29, 1968, King went to Memphis, Tennessee, in support of the black sanitary public works employees, who were represented by AFSCME Local 1733. The workers had been on strike since March 12 for higher wages and better treatment. In one incident, black street repairmen received pay for two hours when they were sent home because of bad weather, but white employees were paid for the full day.[247][248][249] On April 3, King addressed a rally and delivered his "I've Been to the Mountaintop" address[250] at Mason Temple, the world headquarters of the Church of God in Christ. King's flight to Memphis had been delayed by a bomb threat against his plane.[251] In the prophetic peroration of the last speech of his life, in reference to the bomb threat, King said the following: And then I got to Memphis. And some began to say the threats, or talk about the threats that were out. What would happen to me from some of our sick white brothers? Well, I don't know what will happen now. We've got some difficult days ahead. But it doesn't matter with me now. Because I've been to the mountaintop. And I don't mind. Like anybody, I would like to live a long life. Longevity has its place. But I'm not concerned about that now. I just want to do God's will. And He's allowed me to go up to the mountain. And I've looked over. And I've seen the promised land. I may not get there with you. But I want you to know tonight, that we, as a people, will get to the promised land. So I'm happy, tonight. I'm not worried about anything. I'm not fearing any man. Mine eyes have seen the glory of the coming of the Lord.[252] King was booked in Room 306 at the Lorraine Motel (owned by Walter Bailey) in Memphis. Ralph Abernathy, who was present at the assassination, testified to the United States House Select Committee on Assassinations that King and his entourage stayed at Room 306 so often that it was known as the "King-Abernathy suite".[253] According to Jesse Jackson, who was present, King's last words on the balcony before his assassination were spoken to musician Ben Branch, who was scheduled to perform that night at an event King was attending: "Ben, make sure you play 'Take My Hand, Precious Lord' in the meeting tonight. Play it real pretty."[254] King was fatally shot by James Earl Ray at 6:01 p.m., Thursday, April 4, 1968, as he stood on the motel's second-floor balcony. The bullet entered through his right cheek, smashing his jaw, then traveled down his spinal cord before lodging in his shoulder.[255][256] Abernathy heard the shot from inside the motel room and ran to the balcony to find King on the floor.[257] Jackson stated after the shooting that he cradled King's head as King lay on the balcony, but this account was disputed by other colleagues of King; Jackson later changed his statement to say that he had "reached out" for King.[258] After emergency chest surgery, King died at St. Joseph's Hospital at 7:05 p.m.[259] According to biographer Taylor Branch, King's autopsy revealed that though only 39 years old, he "had the heart of a 60 year old", which Branch attributed to the stress of 13 years in the civil rights movement.[260] King was initially interred in South View Cemetery in South Atlanta, but in 1977 his remains were transferred to a tomb on the site of the Martin Luther King Jr. National Historical Park.[261] AftermathFurther information: King assassination riotsThe assassination led to a nationwide wave of race riots in Washington, D.C., Chicago, Baltimore, Louisville, Kansas City, and dozens of other cities.[262][263][264] Presidential candidate Robert F. Kennedy was on his way to Indianapolis for a campaign rally when he was informed of King's death. He gave a short, improvised speech to the gathering of supporters informing them of the tragedy and urging them to continue King's ideal of nonviolence.[265] The following day, he delivered a prepared response in Cleveland.[266] James Farmer Jr. and other civil rights leaders also called for non-violent action, while the more militant Stokely Carmichael called for a more forceful response.[267] The city of Memphis quickly settled the strike on terms favorable to the sanitation workers.[268] The plan to set up a shantytown in Washington, D.C., was carried out soon after the April 4 assassination. Criticism of King's plan was subdued in the wake of his death, and the SCLC received an unprecedented wave of donations for the purpose of carrying it out. The campaign officially began in Memphis, on May 2, at the hotel where King was murdered.[269] Thousands of demonstrators arrived on the National Mall and stayed for six weeks, establishing a camp they called "Resurrection City".[270] President Lyndon B. Johnson tried to quell the riots by making several telephone calls to civil rights leaders, mayors and governors across the United States and told politicians that they should warn the police against the unwarranted use of force.[264] However, his efforts did not work out: "I'm not getting through," Johnson told his aides. "They're all holing up like generals in a dugout getting ready to watch a war."[264] Johnson declared April 7 a national day of mourning for the civil rights leader.[271] Vice President Hubert Humphrey attended King's funeral on behalf of the President, as there were fears that Johnson's presence might incite protests and perhaps violence.[272] At his widow's request, King's last sermon at Ebenezer Baptist Church was played at the funeral,[273] a recording of his "Drum Major" sermon, given on February 4, 1968. In that sermon, King made a request that at his funeral no mention of his awards and honors be made, but that it be said that he tried to "feed the hungry", "clothe the naked", "be right on the [Vietnam] war question", and "love and serve humanity".[274] His good friend Mahalia Jackson sang his favorite hymn, "Take My Hand, Precious Lord", at the funeral.[275] The assassination helped to spur the enactment of the Civil Rights Act of 1968.[264] Two months after King's death, James Earl Ray—who was on the loose from a previous prison escape—was captured at London Heathrow Airport while trying to leave England on a false Canadian passport. He was using the alias Ramon George Sneyd on his way to white-ruled Rhodesia.[276] Ray was quickly extradited to Tennessee and charged with King's murder. He confessed to the assassination on March 10, 1969, though he recanted this confession three days later.[277] On the advice of his attorney Percy Foreman, Ray pleaded guilty to avoid a trial conviction and thus the possibility of receiving the death penalty. He was sentenced to a 99-year prison term.[277][278] Ray later claimed a man he met in Montreal, Quebec, with the alias "Raoul" was involved and that the assassination was the result of a conspiracy.[279][280] He spent the remainder of his life attempting, unsuccessfully, to withdraw his guilty plea and secure the trial he never had.[278] Ray died in 1998 at age 70.[281] Allegations of conspiracyMain article: Martin Luther King Jr. assassination conspiracy theories The sarcophagus for Martin Luther King Jr. and Coretta Scott King is within the Martin Luther King Jr. National Historical Park in Atlanta, Georgia.Ray's lawyers maintained he was a scapegoat similar to the way that John F. Kennedy's assassin Lee Harvey Oswald is seen by conspiracy theorists.[282] Supporters of this assertion said that Ray's confession was given under pressure and that he had been threatened with the death penalty.[278][283] They admitted that Ray was a thief and burglar, but claimed that he had no record of committing violent crimes with a weapon.[280] However, prison records in different U.S. cities have shown that he was incarcerated on numerous occasions for charges of armed robbery.[284] In a 2008 interview with CNN, Jerry Ray, the younger brother of James Earl Ray, claimed that James was smart and was sometimes able to get away with armed robbery. Jerry Ray said that he had assisted his brother on one such robbery. "I never been with nobody as bold as he is," Jerry said. "He just walked in and put that gun on somebody, it was just like it's an everyday thing."[284] Those suspecting a conspiracy in the assassination point to the two successive ballistics tests which proved that a rifle similar to Ray's Remington Gamemaster had been the murder weapon. Those tests did not implicate Ray's specific rifle.[278][285] Witnesses near King at the moment of his death said that the shot came from another location. They said that it came from behind thick shrubbery near the boarding house—which had been cut away in the days following the assassination—and not from the boarding house window.[286] However, Ray's fingerprints were found on various objects (a rifle, a pair of binoculars, articles of clothing, a newspaper) that were left in the bathroom where it was determined the gunfire came from.[284] An examination of the rifle containing Ray's fingerprints determined that at least one shot was fired from the firearm at the time of the assassination.[284] In 1997, King's son Dexter Scott King met with Ray, and publicly supported Ray's efforts to obtain a new trial.[287] Two years later, King's widow Coretta Scott King and the couple's children won a wrongful death claim against Loyd Jowers and "other unknown co-conspirators". Jowers claimed to have received $100,000 to arrange King's assassination. The jury of six whites and six blacks found in favor of the King family, finding Jowers to be complicit in a conspiracy against King and that government agencies were party to the assassination.[288][289] William F. Pepper represented the King family in the trial.[290] In 2000, the U.S. Department of Justice completed the investigation into Jowers' claims but did not find evidence to support allegations about conspiracy. The investigation report recommended no further investigation unless some new reliable facts are presented.[291] A sister of Jowers admitted that he had fabricated the story so he could make $300,000 from selling the story, and she in turn corroborated his story in order to get some money to pay her income tax.[292][293] In 2002, The New York Times reported that a church minister, Ronald Denton Wilson, claimed his father, Henry Clay Wilson—not James Earl Ray—assassinated King. He stated, "It wasn't a racist thing; he thought Martin Luther King was connected with communism, and he wanted to get him out of the way." Wilson provided no evidence to back up his claims.[294] King researchers David Garrow and Gerald Posner disagreed with William F. Pepper's claims that the government killed King.[295] In 2003, Pepper published a book about the long investigation and trial, as well as his representation of James Earl Ray in his bid for a trial, laying out the evidence and criticizing other accounts.[296][297] King's friend and colleague, James Bevel, also disputed the argument that Ray acted alone, stating, "There is no way a ten-cent white boy could develop a plan to kill a million-dollar black man."[298] In 2004, Jesse Jackson stated: The fact is there were saboteurs to disrupt the march. And within our own organization, we found a very key person who was on the government payroll. So infiltration within, saboteurs from without and the press attacks. ... I will never believe that James Earl Ray had the motive, the money and the mobility to have done it himself. Our government was very involved in setting the stage for and I think the escape route for James Earl Ray.[299] LegacySee also: Memorials to Martin Luther King Jr. and List of streets named after Martin Luther King Jr. Martin Luther King Jr. statue over the west entrance of Westminster Abbey, installed in 1998South AfricaSee also: Black Consciousness MovementKing's legacy includes influences on the Black Consciousness Movement and civil rights movement in South Africa.[300][301] King's work was cited by, and served as, an inspiration for South African leader Albert Lutuli, who fought for racial justice in his country during apartheid and was later awarded the Nobel Peace Prize.[302] United KingdomSee also: Northern Ireland civil rights movementKing influenced Irish politician and activist John Hume. Hume, the former leader of the Social Democratic and Labour Party, cited King's legacy as quintessential to the Northern Irish civil rights movement and the signing of the Good Friday Agreement, calling him "one of my great heroes of the century".[303][304][305] The Martin Luther King Fund and Foundation in the UK was set up as a charity[306] on December 30, 1969, after the assassination of Martin Luther King Jr. and following a visit to the UK in 1969 by his widow, Coretta King. The Foundation's first chairman, Canon. L. John Collins, stated that the Foundation was to be an active UK national campaign for racial equality, its work also to include community projects in areas of social need, and education.[307] International Personnel (IP), an employment agency, was formed in 1970 out of the foundation's base in Balham, in London's Inner Ring South, to find employment for professionally qualified black people. In its first year, the agency placed ten percent of its applicants in jobs equal to their ability.[308] The Balham Training Scheme operated an evening school at the premises in South London and had a director, co-ordinator and five lecturers in Typing, Shorthand, English and Maths.[307] The 1975 Martin Luther King Memorial Lecture, entitled 'Black People and Employment', was given in the Mahatma Gandhi Hall of the Indian YMCA in London on May 6, 1975, by The Rt. Rev David Sheppard who was chairman of the fund until his appointment as Bishop of Liverpool in June 1975.[307] In the late 1970s Wilfred Wood, a Barbadian-British Anglican, Bishop of Croydon from 1985 to 2003, the first black bishop in the Church of England, and instrumental in the establishment of the foundation, became its chair. Wood was second in the "100 Great Black Britons" list in 2004.[309] The 1989 Martin Luther King Memorial Lecture, entitled 'To Overcome is to Undertake', was given by the Rt Rev. Wilfred Wood, Bishop of Croydon. The text is still available.[308] The foundation was removed from the Charity Commission list on November 18, 1996, as it had ceased to exist.[306] In the United Kingdom today, The Northumbria and Newcastle Universities Martin Luther King Peace Committee[310] still exists to honor King's legacy, as represented by his final visit to the UK to receive an honorary degree from Newcastle University in 1967.[311][312] The Peace Committee operates out of the chaplaincies of the city's two universities, Northumbria and Newcastle, both of which remain centres for the study of Martin Luther King and the US civil rights movement. Inspired by King's vision, it undertakes a range of activities across the UK as it seeks to "build cultures of peace". In 2017, Newcastle University unveiled a bronze statue of King to celebrate the 50th anniversary of his honorary doctorate ceremony.[313] The Students Union also voted to rename their bar Luthers.[314] United States Banner at the 2012 Republican National ConventionKing has become a national icon in the history of American liberalism and American progressivism.[315] His main legacy was to secure progress on civil rights in the U.S. Just days after King's assassination, Congress passed the Civil Rights Act of 1968.[316] Title VIII of the Act, commonly known as the Fair Housing Act, prohibited discrimination in housing and housing-related transactions on the basis of race, religion, or national origin (later expanded to include sex, familial status, and disability). This legislation was seen as a tribute to King's struggle in his final years to combat residential discrimination in the U.S.[316] The day following King's assassination, school teacher Jane Elliott conducted her first "Blue Eyes/Brown Eyes" exercise with her class of elementary school students in Riceville, Iowa. Her purpose was to help them understand King's death as it related to racism, something they little understood as they lived in a predominantly white community.[317] King's wife Coretta Scott King followed in her husband's footsteps and was active in matters of social justice and civil rights until her death in 2006. The same year that Martin Luther King was assassinated, she established the King Center in Atlanta, Georgia, dedicated to preserving his legacy and the work of championing nonviolent conflict resolution and tolerance worldwide.[318] Their son, Dexter King, serves as the center's chairman.[319][320] Daughter Yolanda King, who died in 2007, was a motivational speaker, author and founder of Higher Ground Productions, an organization specializing in diversity training.[321] Even within the King family, members disagree about his religious and political views about gay, lesbian, bisexual and transgender people. King's widow Coretta publicly said that she believed her husband would have supported gay rights.[322] However, his youngest child, Bernice King, has said publicly that he would have been opposed to gay marriage.[323] On February 4, 1968, at the Ebenezer Baptist Church, in speaking about how he wished to be remembered after his death, King stated: I'd like somebody to mention that day that Martin Luther King Jr. tried to give his life serving others. I'd like for somebody to say that day that Martin Luther King Jr. tried to love somebody. I want you to say that day that I tried to be right on the war question. I want you to be able to say that day that I did try to feed the hungry. I want you to be able to say that day that I did try in my life to clothe those who were naked. I want you to say on that day that I did try in my life to visit those who were in prison. And I want you to say that I tried to love and serve humanity. Yes, if you want to say that I was a drum major. Say that I was a drum major for justice. Say that I was a drum major for peace. I was a drum major for righteousness. And all of the other shallow things will not matter. I won't have any money to leave behind. I won't have the fine and luxurious things of life to leave behind. But I just want to leave a committed life behind.[267][324] Martin Luther King Jr. DayMain article: Martin Luther King Jr. DayBeginning in 1971, cities such as St. Louis, Missouri, and states established annual holidays to honor King.[325] At the White House Rose Garden on November 2, 1983, President Ronald Reagan signed a bill creating a federal holiday to honor King. Observed for the first time on January 20, 1986, it is called Martin Luther King Jr. Day. Following President George H. W. Bush's 1992 proclamation, the holiday is observed on the third Monday of January each year, near the time of King's birthday.[326][327] On January 17, 2000, for the first time, Martin Luther King Jr. Day was officially observed in all fifty U.S. states.[328] Arizona (1992), New Hampshire (1999) and Utah (2000) were the last three states to recognize the holiday. Utah previously celebrated the holiday at the same time but under the name Human Rights Day.[329] VenerationMartin Luther King of GeorgiaPastor and MartyrHonored inHoly Christian Orthodox ChurchEpiscopal Church (United States)Evangelical Lutheran Church in AmericaCanonizedSeptember 9, 2016, The Christian Cathedral by Timothy Paul BaymonFeastApril 4January 15 (Episcopalian and Lutheran)King was canonized by Archbishop Timothy Paul of the Holy Christian Orthodox Church (not to be confused with the Eastern Orthodox Church) on September 9, 2016, at the Christian Cathedral in Springfield, Massachusetts.[330][331][332][333][334] His feast day was set as April 4, the date of his assassination. King is also honored with a Lesser Feast on the liturgical calendar of the Episcopal Church[335] on April 4 or January 15, the anniversary of his birth. The Evangelical Lutheran Church in America commemorates King liturgically on January 15.[336] Ideas, influences, and political stancesChristianity King at the 1963 Civil Rights March in Washington, D.C.As a Christian minister, King's main influence was Jesus Christ and the Christian gospels, which he would almost always quote in his religious meetings, speeches at church, and in public discourses. King's faith was strongly based in Jesus' commandment of loving your neighbor as yourself, loving God above all, and loving your enemies, praying for them and blessing them. His nonviolent thought was also based in the injunction to turn the other cheek in the Sermon on the Mount, and Jesus' teaching of putting the sword back into its place (Matthew 26:52).[337] In his famous Letter from Birmingham Jail, King urged action consistent with what he describes as Jesus' "extremist" love, and also quoted numerous other Christian pacifist authors, which was very usual for him. In another sermon, he stated: Before I was a civil rights leader, I was a preacher of the Gospel. This was my first calling and it still remains my greatest commitment. You know, actually all that I do in civil rights I do because I consider it a part of my ministry. I have no other ambitions in life but to achieve excellence in the Christian ministry. I don't plan to run for any political office. I don't plan to do anything but remain a preacher. And what I'm doing in this struggle, along with many others, grows out of my feeling that the preacher must be concerned about the whole man.[338][339] King's private writings show that he rejected biblical literalism; he described the Bible as "mythological", doubted that Jesus was born of a virgin, suggested he may not have been bodily resurrected, and did not believe that the story of Jonah and the whale was true.[340] The Measure of a ManIn 1959, King published a short book called The Measure of a Man, which contained his sermons "What is Man?" and "The Dimensions of a Complete Life". The sermons argued for man's need for God's love and criticized the racial injustices of Western civilization.[341] NonviolenceA close-up of RustinKing worked alongside Quakers such as Bayard Rustin to develop nonviolent tactics.World peace through nonviolent means is neither absurd nor unattainable. All other methods have failed. Thus we must begin anew. Nonviolence is a good starting point. Those of us who believe in this method can be voices of reason, sanity, and understanding amid the voices of violence, hatred, and emotion. We can very well set a mood of peace out of which a system of peace can be built. —Martin Luther King Jr.[342]Veteran African-American civil rights activist Bayard Rustin was King's first regular advisor on nonviolence.[343] King was also advised by the white activists Harris Wofford and Glenn Smiley.[344] Rustin and Smiley came from the Christian pacifist tradition, and Wofford and Rustin both studied Mahatma Gandhi's teachings. Rustin had applied nonviolence with the Journey of Reconciliation campaign in the 1940s,[345] and Wofford had been promoting Gandhism to Southern blacks since the early 1950s.[344] King had initially known little about Gandhi and rarely used the term "nonviolence" during his early years of activism in the early 1950s. King initially believed in and practiced self-defense, even obtaining guns in his household as a means of defense against possible attackers. The pacifists guided King by showing him the alternative of nonviolent resistance, arguing that this would be a better means to accomplish his goals of civil rights than self-defense. King then vowed to no longer personally use arms.[346][347] In the aftermath of the boycott, King wrote Stride Toward Freedom, which included the chapter Pilgrimage to Nonviolence. King outlined his understanding of nonviolence, which seeks to win an opponent to friendship, rather than to humiliate or defeat him. The chapter draws from an address by Wofford, with Rustin and Stanley Levison also providing guidance and ghostwriting.[348] King was inspired by Gandhi and his success with nonviolent activism, and as a theology student, King described Gandhi as being one of the "individuals who greatly reveal the working of the Spirit of God".[349] King had "for a long time ... wanted to take a trip to India."[350] With assistance from Harris Wofford, the American Friends Service Committee, and other supporters, he was able to fund the journey in April 1959.[351][352] The trip to India affected King, deepening his understanding of nonviolent resistance and his commitment to America's struggle for civil rights. In a radio address made during his final evening in India, King reflected, "Since being in India, I am more convinced than ever before that the method of nonviolent resistance is the most potent weapon available to oppressed people in their struggle for justice and human dignity." King's admiration of Gandhi's nonviolence did not diminish in later years. He went so far as to hold up his example when receiving the Nobel Peace Prize in 1964, hailing the "successful precedent" of using nonviolence "in a magnificent way by Mohandas K. Gandhi to challenge the might of the British Empire ... He struggled only with the weapons of truth, soul force, non-injury and courage."[353] Another influence for King's nonviolent method was Henry David Thoreau's essay On Civil Disobedience and its theme of refusing to cooperate with an evil system.[354] He also was greatly influenced by the works of Protestant theologians Reinhold Niebuhr and Paul Tillich,[355] and said that Walter Rauschenbusch's Christianity and the Social Crisis left an "indelible imprint" on his thinking by giving him a theological grounding for his social concerns.[356][357] King was moved by Rauschenbusch's vision of Christians spreading social unrest in "perpetual but friendly conflict" with the state, simultaneously critiquing it and calling it to act as an instrument of justice.[358] However, he was apparently unaware of the American tradition of Christian pacifism exemplified by Adin Ballou and William Lloyd Garrison.[359] King frequently referred to Jesus' Sermon on the Mount as central for his work.[357][360][361][362] King also sometimes used the concept of "agape" (brotherly Christian love).[363] However, after 1960, he ceased employing it in his writings.[364] Even after renouncing his personal use of guns, King had a complex relationship with the phenomenon of self-defense in the movement. He publicly discouraged it as a widespread practice, but acknowledged that it was sometimes necessary.[365] Throughout his career King was frequently protected by other civil rights activists who carried arms, such as Colonel Stone Johnson,[366] Robert Hayling, and the Deacons for Defense and Justice.[367][368] Criticism within the movementKing was criticized by other black leaders during the course of his participation in the civil rights movement. This included opposition by more militant thinkers such as Nation of Islam member Malcolm X.[369] Student Nonviolent Coordinating Committee founder Ella Baker regarded King as a charismatic media figure who lost touch with the grassroots of the movement[370] as he became close to elite figures like Nelson Rockefeller.[371] Stokely Carmichael, a protege of Baker's, became a black separatist and disagreed with King's plea for racial integration because he considered it an insult to a uniquely African-American culture.[372][373] He also took issue that King's non-violence approach depended on appealing to America's conscience, feeling America had none to appeal to.[374] Activism and involvement with Native AmericansKing was an avid supporter of Native American rights. Native Americans were also active supporters of King's civil rights movement which included the active participation of Native Americans.[375] In fact, the Native American Rights Fund (NARF) was patterned after the NAACP's Legal Defense and Education Fund.[376] The National Indian Youth Council (NIYC) was especially supportive in King's campaigns especially the Poor People's Campaign in 1968.[377] In King's book Why We Can't Wait he writes: Our nation was born in genocide when it embraced the doctrine that the original American, the Indian, was an inferior race. Even before there were large numbers of Negroes on our shores, the scar of racial hatred had already disfigured colonial society. From the sixteenth century forward, blood flowed in battles over racial supremacy. We are perhaps the only nation which tried as a matter of national policy to wipe out its indigenous population. Moreover, we elevated that tragic experience into a noble crusade. Indeed, even today we have not permitted ourselves to reject or to feel remorse for this shameful episode. Our literature, our films, our drama, our folklore all exalt it.[378] King assisted Native American people in south Alabama in the late 1950s.[376] At that time the remaining Creek in Alabama were trying to completely desegregate schools in their area. The South had many racial problems: In this case, light-complexioned Native children were allowed to ride school buses to previously all white schools, while dark-skinned Native children from the same band were barred from riding the same buses.[376] Tribal leaders, upon hearing of King's desegregation campaign in Birmingham, Alabama, contacted him for assistance. He promptly responded and through his intervention the problem was quickly resolved.[376] In September 1959, King flew from Los Angeles, California, to Tucson, Arizona.[379] After giving a speech at the University of Arizona on the ideals of using nonviolent methods in creating social change. He put into words his belief that one must not use force in this struggle "but match the violence of his opponents with his suffering."[379] King then went to Southside Presbyterian, a predominantly Native American church, and was fascinated by their photos. On the spur of the moment, King wanted to go to an Indian Reservation to meet the people so Casper Glenn took King to the Papago Indian Reservation.[379] At the reservation King met with all the tribal leaders, and others on the reservation then ate with them.[379] King then visited another Presbyterian church near the reservation, and preached there attracting a Native American crowd.[379] He later returned to Old Pueblo in March 1962 where he preached again to a Native American congregation, and then went on to give another speech at the University of Arizona.[379] King would continue to attract the attention of Native Americans throughout the civil rights movement. During the 1963 March on Washington there was a sizable Native American contingent, including many from South Dakota, and many from the Navajo nation.[376][380] Native Americans were also active participants in the Poor People's Campaign in 1968.[377] King was a major inspiration, along with the civil rights movement, of the Native American rights movement of the 1960s and many of its leaders.[376] John Echohawk, a member of the Pawnee tribe who was the executive director and a founder of the Native American Rights Fund, stated: Inspired by Dr. King, who was advancing the civil rights agenda of equality under the laws of this country, we thought that we could also use the laws to advance our Indianship, to live as tribes in our territories governed by our own laws under the principles of tribal sovereignty that had been with us ever since 1831. We believed that we could fight for a policy of self-determination that was consistent with U.S. law and that we could govern our own affairs, define our own ways and continue to survive in this society.[381] PoliticsAs the leader of the SCLC, King maintained a policy of not publicly endorsing a U.S. political party or candidate: "I feel someone must remain in the position of non-alignment, so that he can look objectively at both parties and be the conscience of both—not the servant or master of either."[382] In a 1958 interview, he expressed his view that neither party was perfect, saying, "I don't think the Republican party is a party full of the almighty God nor is the Democratic party. They both have weaknesses ... And I'm not inextricably bound to either party."[383] King did praise Democratic Senator Paul Douglas of Illinois as being the "greatest of all senators" because of his fierce advocacy for civil rights causes over the years.[384] King critiqued both parties' performance on promoting racial equality: Actually, the Negro has been betrayed by both the Republican and the Democratic party. The Democrats have betrayed him by capitulating to the whims and caprices of the Southern Dixiecrats. The Republicans have betrayed him by capitulating to the blatant hypocrisy of reactionary right-wing northern Republicans. And this coalition of southern Dixiecrats and right-wing reactionary northern Republicans defeats every bill and every move towards liberal legislation in the area of civil rights.[385] Although King never publicly supported a political party or candidate for president, in a letter to a civil rights supporter in October 1956 he said that he had not decided whether he would vote for Democrat Adlai Stevenson II or Republican Dwight D. Eisenhower at the 1956 presidential election, but that "In the past, I always voted the Democratic ticket."[386] In his autobiography, King says that in 1960 he privately voted for Democratic candidate John F. Kennedy: "I felt that Kennedy would make the best president. I never came out with an endorsement. My father did, but I never made one." King adds that he likely would have made an exception to his non-endorsement policy for a second Kennedy term, saying "Had President Kennedy lived, I would probably have endorsed him in 1964."[387] In 1964, King urged his supporters "and all people of goodwill" to vote against Republican Senator Barry Goldwater for president, saying that his election "would be a tragedy, and certainly suicidal almost, for the nation and the world."[388] King supported the ideals of democratic socialism, although he was reluctant to speak directly of this support due to the anti-communist sentiment being projected throughout the United States at the time, and the association of socialism with communism. King believed that capitalism could not adequately provide the necessities of many American people, particularly the African-American community.[389][390][391][229] King expressed that "the evils of capitalism are as real as the evils of militarism and evils of racism".[392][393] King was critical of American culture saying "when machines and computers, profit motives and property rights are considered more important than people, the giant triplets of racism, materialism and militarism are incapable of being conquered" and that America must undergo a "radical revolution of values".[394][395] King considered that in America "the problem is that we all to often have socialism for the rich and rugged free enterprise capitalism for the poor".[396][397] In a 1952 letter to Coretta Scott, he said: "I imagine you already know that I am much more socialistic in my economic theory than capitalistic ..."[398][389] In one speech, he stated that "something is wrong with capitalism" and said, "There must be a better distribution of wealth, and maybe America must move toward a democratic socialism."[399] King further said that "capitalism has outlived its usefulness" and "failed to meet the needs of the masses".[400] King had read Marx while at Morehouse, but while he rejected "traditional capitalism", he rejected communism because of its "materialistic interpretation of history" that denied religion, its "ethical relativism", and its "political totalitarianism".[401] CompensationSee also: Reparations for slavery debate in the United StatesKing stated that black Americans, as well as other disadvantaged Americans, should be compensated for historical wrongs. In an interview conducted for Playboy in 1965, he said that granting black Americans only equality could not realistically close the economic gap between them and whites. King said that he did not seek a full restitution of wages lost to slavery, which he believed impossible, but proposed a government compensatory program of $50 billion over ten years to all disadvantaged groups.[402] He posited that "the money spent would be more than amply justified by the benefits that would accrue to the nation through a spectacular decline in school dropouts, family breakups, crime rates, illegitimacy, swollen relief rolls, rioting and other social evils."[403] He presented this idea as an application of the common law regarding settlement of unpaid labor, but clarified that he felt that the money should not be spent exclusively on blacks. He stated, "It should benefit the disadvantaged of all races."[404] TelevisionActress Nichelle Nichols planned to leave the science-fiction television series Star Trek in 1967 after its first season, wanting to return to musical theater.[405] She changed her mind after talking to King[406] who was a fan of the show. King explained that her character signified a future of greater racial harmony and cooperation.[407] King told Nichols, "You are our image of where we're going, you're 300 years from now, and that means that's where we are and it takes place now. Keep doing what you're doing, you are our inspiration."[408] As Nichols recounted, "Star Trek was one of the only shows that [King] and his wife Coretta would allow their little children to watch. And I thanked him and I told him I was leaving the show. All the smile came off his face. And he said, 'Don't you understand for the first time we're seen as we should be seen. You don't have a black role. You have an equal role.'"[405] For his part, the series' creator, Gene Roddenberry, was deeply moved upon learning of King's support.[409] State surveillance and coercionFBI surveillance and wiretapping Memo describing FBI attempts to disrupt the Poor People's Campaign with fraudulent claims about King‍—‌part of the COINTELPRO campaign against the anti-war and civil rights movementsFBI director J. Edgar Hoover personally ordered surveillance of King, with the intent to undermine his power as a civil rights leader.[410][411] The Church Committee, a 1975 investigation by the U.S. Congress, found that "From December 1963 until his death in 1968, Martin Luther King Jr. was the target of an intensive campaign by the Federal Bureau of Investigation to 'neutralize' him as an effective civil rights leader."[412] In the fall of 1963, the FBI received authorization from Attorney General Robert F. Kennedy to proceed with wiretapping of King's phone lines, purportedly due to his association with Stanley Levison.[413] The Bureau informed President John F. Kennedy. He and his brother unsuccessfully tried to persuade King to dissociate himself from Levison, a New York lawyer who had been involved with Communist Party USA.[414][415] Although Robert Kennedy only gave written approval for limited wiretapping of King's telephone lines "on a trial basis, for a month or so",[416] Hoover extended the clearance so his men were "unshackled" to look for evidence in any areas of King's life they deemed worthy.[115] The Bureau placed wiretaps on the home and office phone lines of both Levison and King, and bugged King's rooms in hotels as he traveled across the country.[414][417] In 1967, Hoover listed the SCLC as a black nationalist hate group, with the instructions: "No opportunity should be missed to exploit through counterintelligence techniques the organizational and personal conflicts of the leaderships of the groups ... to insure [sic] the targeted group is disrupted, ridiculed, or discredited."[411][418] NSA monitoring of King's communicationsIn a secret operation code-named "Minaret", the National Security Agency monitored the communications of leading Americans, including King, who were critical of the U.S. war in Vietnam.[419] A review by the NSA itself concluded that Minaret was "disreputable if not outright illegal".[419] Allegations of communismFor years, Hoover had been suspicious of potential influence of communists in social movements such as labor unions and civil rights.[420] Hoover directed the FBI to track King in 1957, and the SCLC when it was established.[3] Due to the relationship between King and Stanley Levison, the FBI feared Levison was working as an "agent of influence" over King, in spite of its own reports in 1963 that Levison had left the Party and was no longer associated in business dealings with them.[421] Another King lieutenant, Jack O'Dell, was also linked to the Communist Party by sworn testimony before the House Un-American Activities Committee (HUAC).[422] Despite the extensive surveillance conducted, by 1976 the FBI had acknowledged that it had not obtained any evidence that King himself or the SCLC were actually involved with any communist organizations.[412] For his part, King adamantly denied having any connections to communism. In a 1965 Playboy interview, he stated that "there are as many Communists in this freedom movement as there are Eskimos in Florida."[423] He argued that Hoover was "following the path of appeasement of political powers in the South" and that his concern for communist infiltration of the civil rights movement was meant to "aid and abet the salacious claims of southern racists and the extreme right-wing elements."[412] Hoover did not believe King's pledge of innocence and replied by saying that King was "the most notorious liar in the country".[424] After King gave his "I Have A Dream" speech during the March on Washington on August 28, 1963, the FBI described King as "the most dangerous and effective Negro leader in the country".[417] It alleged that he was "knowingly, willingly and regularly cooperating with and taking guidance from communists."[425] The attempts to prove that King was a communist was related to the feeling of many segregationists that blacks in the South were content with the status quo, but had been stirred up by "communists" and "outside agitators".[426] As context, the civil rights movement in 1950s and '60s arose from activism within the black community dating back to before World War I. King said that "the Negro revolution is a genuine revolution, born from the same womb that produces all massive social upheavals—the womb of intolerable conditions and unendurable situations."[427] CIA surveillanceCIA files declassified in 2017 revealed that the agency was investigating possible links between King and Communism after a Washington Post article dated November 4, 1964, claimed he was invited to the Soviet Union and that Ralph Abernathy, as spokesman for King, refused to comment on the source of the invitation.[428] Mail belonging to King and other civil rights activists was intercepted by the CIA program HTLINGUAL.[429] Allegations of adultery The only meeting of King and Malcolm X, outside the United States Senate chamber, March 26, 1964, during the Senate debates regarding the (eventual) Civil Rights Act of 1964[430]The FBI, having concluded that King was dangerous due to communist infiltration, began attempting to discredit King through revelations regarding his private life. FBI surveillance of King, some of it since made public, attempted to demonstrate that he also had numerous extramarital affairs.[417] Lyndon B. Johnson once said that King was a "hypocritical preacher".[431] In his 1989 autobiography And the Walls Came Tumbling Down, Ralph Abernathy stated that King had a "weakness for women", although they "all understood and believed in the biblical prohibition against sex outside of marriage. It was just that he had a particularly difficult time with that temptation."[432] In a later interview, Abernathy said that he only wrote the term "womanizing", that he did not specifically say King had extramarital sex and that the infidelities King had were emotional rather than sexual.[433] Abernathy criticized the media for sensationalizing the statements he wrote about King's affairs,[433] such as the allegation that he admitted in his book that King had a sexual affair the night before he was assassinated.[433] In his original wording, Abernathy had stated that he saw King coming out of his room with a woman when he awoke the next morning and later said that "he may have been in there discussing and debating and trying to get her to go along with the movement, I don't know...the Sanitation Worker's Strike."[433] In his 1986 book Bearing the Cross, David Garrow wrote about a number of extramarital affairs, including one woman King saw almost daily. According to Garrow, "that relationship ... increasingly became the emotional centerpiece of King's life, but it did not eliminate the incidental couplings ... of King's travels." He alleged that King explained his extramarital affairs as "a form of anxiety reduction". Garrow asserted that King's supposed promiscuity caused him "painful and at times overwhelming guilt".[434] King's wife Coretta appeared to have accepted his affairs with equanimity, saying once that "all that other business just doesn't have a place in the very high-level relationship we enjoyed."[435] Shortly after Bearing the Cross was released, civil rights author Howell Raines gave the book a positive review but opined that Garrow's allegations about King's sex life were "sensational" and stated that Garrow was "amassing facts rather than analyzing them".[436] The FBI distributed reports regarding such affairs to the executive branch, friendly reporters, potential coalition partners and funding sources of the SCLC, and King's family.[437] The bureau also sent anonymous letters to King threatening to reveal information if he did not cease his civil rights work.[438] The FBI–King suicide letter sent to King just before he received the Nobel Peace Prize read, in part: The FBI–King suicide letter,[439] mailed anonymously by the FBIThe American public, the church organizations that have been helping—Protestants, Catholics and Jews will know you for what you are—an evil beast. So will others who have backed you. You are done. King, there is only one thing left for you to do. You know what it is. You have just 34 days in which to do (this exact number has been selected for a specific reason, it has definite practical significant [sic]). You are done. There is but one way out for you. You better take it before your filthy fraudulent self is bared to the nation.[440] The letter was accompanied by a tape recording—excerpted from FBI wiretaps—of several of King's extramarital liaisons.[441] King interpreted this package as an attempt to drive him to suicide,[442] although William Sullivan, head of the Domestic Intelligence Division at the time, argued that it may have only been intended to "convince Dr. King to resign from the SCLC."[412] King refused to give in to the FBI's threats.[417] In 1977, Judge John Lewis Smith Jr. ordered all known copies of the recorded audiotapes and written transcripts resulting from the FBI's electronic surveillance of King between 1963 and 1968 to be held in the National Archives and sealed from public access until 2027.[443] In May 2019, an FBI file emerged on which a handwritten note alleged that King "looked on, laughed and offered advice" as one of his friends raped a woman. Expert professional historians of the period who have examined this notional evidence have dismissed it as highly unreliable.[444][445] David Garrow, author of an earlier biography of King, wrote that "the suggestion... that he either actively tolerated or personally employed violence against any woman, even while drunk, poses so fundamental a challenge to his historical stature as to require the most complete and extensive historical review possible".[446][445] Garrow's reliance on a handwritten note addended to a typed report is considered poor scholarship by several other authorities. The Professor of American Studies at the University of Nottingham, Peter Ling, pointed out that Garrow was excessively credulous, if not naive, in accepting the accuracy of FBI reports during a period when the FBI was undertaking a massive operation to attempt to discredit King as part of its COINTELPRO activities.[447] Garrow had earlier referred to Ling's work on King, widely considered authoritative, as "thoughtful, perceptive, and thoroughly well-informed".[448] Experts in 20th-century American history, including Distinguished Professor of Political Science Jeanne Theoharis, the professors Barbara Ransby of the University of Illinois at Chicago, Nathan Connolly of Johns Hopkins University and Professor Emeritus of History Glenda Gilmore of Yale University have expressed reservations about Garrow's scholarship. Theoharis commented "Most scholars I know would penalize graduate students for doing this." It is not the first time the care and rigor of Garrow's work has been called into serious question.[449] Clayborne Carson, Martin Luther King biographer and overseer of the Dr. King records at Stanford University states that he came to the opposite conclusion of Garrow saying "None of this is new. Garrow is talking about a recently added summary of a transcript of a 1964 recording from the Willard Hotel that others, including Mrs. King, have said they did not hear Martin's voice on it. The added summary was four layers removed from the actual recording. This supposedly new information comes from an anonymous source in a single paragraph in an FBI report. You have to ask how could anyone conclude King looked at a rape from an audio recording in a room where he was not present."[450] Carson bases his position of Coretta Scott King's memoirs where she states "I set up our reel-to-reel recorder and listened. I have read scores of reports talking about the scurrilous activities of my husband but once again, there was nothing at all incriminating on the tape. It was a social event with people laughing and telling dirty jokes. But I did not hear Martin's voice on it, and there was nothing about sex or anything else resembling the lies J. Edgar and the FBI were spreading." The tapes that could confirm or refute the allegation are scheduled to be declassified in 2027.[451] Police observation during the assassinationA fire station was located across from the Lorraine Motel, next to the boarding house in which James Earl Ray was staying. Police officers were stationed in the fire station to keep King under surveillance.[452] Agents were watching King at the time he was shot.[453] Immediately following the shooting, officers rushed out of the station to the motel. Marrell McCollough, an undercover police officer, was the first person to administer first aid to King.[454] The antagonism between King and the FBI, the lack of an all points bulletin to find the killer, and the police presence nearby led to speculation that the FBI was involved in the assassination.[455] Awards and recognition King showing his medallion, which he received from Mayor Wagner, 1964King was awarded at least fifty honorary degrees from colleges and universities.[456] On October 14, 1964, King became the youngest winner of the Nobel Peace Prize, which was awarded to him for leading nonviolent resistance to racial prejudice in the U.S.[457][458] In 1965, he was awarded the American Liberties Medallion by the American Jewish Committee for his "exceptional advancement of the principles of human liberty."[456][459] In his acceptance remarks, King said, "Freedom is one thing. You have it all or you are not free."[460] In 1957, he was awarded the Spingarn Medal from the NAACP.[461] Two years later, he won the Anisfield-Wolf Book Award for his book Stride Toward Freedom: The Montgomery Story.[462] In 1966, the Planned Parenthood Federation of America awarded King the Margaret Sanger Award for "his courageous resistance to bigotry and his lifelong dedication to the advancement of social justice and human dignity."[463] Also in 1966, King was elected as a fellow of the American Academy of Arts and Sciences.[464] In November 1967, he made a 24-hour trip to the United Kingdom to receive an honorary Doctorate in Civil Law from Newcastle University, becoming the first African American the institution had recognised in this way.[312] In a moving impromptu acceptance speech,[311] he said There are three urgent and indeed great problems that we face not only in the United States of America but all over the world today. That is the problem of racism, the problem of poverty and the problem of war. King after receiving his honorary doctorate from Newcastle UniversityIn addition to his nominations for three Grammy Awards, King posthumously won for Best Spoken Word Recording in 1971 for "Why I Oppose The War In Vietnam".[465] In 1977, the Presidential Medal of Freedom was posthumously awarded to King by President Jimmy Carter. The citation read: Martin Luther King Jr. was the conscience of his generation. He gazed upon the great wall of segregation and saw that the power of love could bring it down. From the pain and exhaustion of his fight to fulfill the promises of our founding fathers for our humblest citizens, he wrung his eloquent statement of his dream for America. He made our nation stronger because he made it better. His dream sustains us yet.[466] King and his wife were also awarded the Congressional Gold Medal in 2004.[467] King was second in Gallup's List of Most Widely Admired People of the 20th Century.[468] In 1963, he was named Time Person of the Year, and, in 2000, he was voted sixth in an online "Person of the Century" poll by the same magazine.[469] King placed third in the Greatest American contest conducted by the Discovery Channel and AOL.[470] Five-dollar billOn April 20, 2016, Treasury Secretary Jacob Lew announced that the $5, $10, and $20 bills would all undergo redesign prior to 2020. Lew said that while Lincoln would remain on the front of the $5 bill, the reverse would be redesigned to depict various historical events that had occurred at the Lincoln Memorial. Among the planned designs are images from King's "I Have a Dream" speech and the 1939 concert by opera singer Marian Anderson.[471] MemorialsMain article: List of memorials to Martin Luther King Jr.Many memorial sites, buildings and sculptures have been created to honor Martin Luther King Jr, including the Martin Luther King Jr. Memorial Library in Washington, D.C.,[472] the Dr. Martin Luther King Jr. Library, located in downtown San Jose, California, and the Martin Luther King Jr. Memorial located in West Potomac Park next to the National Mall in Washington, D.C., many other memorials have been made in The United States of America and in other countries to honor his legacy. WorksStride Toward Freedom: The Montgomery Story (1958) ISBN 978-0-06-250490-6The Measure of a Man (1959) ISBN 978-0-8006-0877-4Strength to Love (1963) ISBN 978-0-8006-9740-2Why We Can't Wait (1964) ISBN 978-0-8070-0112-7Where Do We Go from Here: Chaos or Community? (1967) ISBN 978-0-8070-0571-2The Trumpet of Conscience (1968) ISBN 978-0-8070-0170-7A Testament of Hope: The Essential Writings and Speeches of Martin Luther King Jr. (1986) ISBN 978-0-06-250931-4The Autobiography of Martin Luther King Jr. (1998), ed. Clayborne Carson ISBN 978-0-446-67650-2"All Labor Has Dignity" (2011) ed. Michael Honey ISBN 978-0-8070-8600-1"Thou, Dear God": Prayers That Open Hearts and Spirits. Collection of King's prayers. (2011), ed. Lewis Baldwin ISBN 978-0-8070-8603-2MLK: A Celebration in Word and Image (2011). Photographed by Bob Adelman, introduced by Charles Johnson ISBN 978-0-8070-0316-9DiscographyAlbumsCharted albums by Martin Luther King Jr.TitleYearPeakUS[473]The Great March to Freedom1963141The March on Washington102Freedom March on Washington119I Have a Dream196869The American Dream173In Search of Freedom150In the Struggle for Freedom and Human Dignity154SinglesCharted singles by Martin Luther King Jr.TitleYearPeakAlbumUS[473]"I Have a Dream"(Gordy 7023 – b/w We Shall Overcome, Liz Lands) 196888I Have a Dream (1968) Civil disobedience is the active, professed refusal of a citizen to obey certain laws, demands, orders or commands of a government (or any other authority). By some definitions, civil disobedience has to be nonviolent to be called "civil". Hence, civil disobedience is sometimes equated with peaceful protests or nonviolent resistance.[1][2] Henry David Thoreau's essay Resistance to Civil Government, published posthumously as Civil Disobedience, popularized the term in the US, although the concept itself has been practiced longer before. It has inspired leaders such as Susan B. Anthony of the U.S. women's suffrage movement in the late 1800s, Saad Zaghloul in the 1910s culminating in Egyptian Revolution of 1919 against British Occupation, and Mahatma Gandhi in 1920s India in their protests for Indian independence against the British Empire. Martin Luther King Jr.'s and James Bevel's peaceful protests during the civil rights movement in the 1960s United States contained important aspects of civil disobedience. Although civil disobedience is rarely justifiable in court,[3] King regarded civil disobedience to be a display and practice of reverence for law: "Any man who breaks a law that conscience tells him is unjust and willingly accepts the penalty by staying in jail to arouse the conscience of the community on the injustice of the law is at that moment expressing the very highest respect for the law."[4] HistoryAn early depiction of civil disobedience is in Sophocles' play Antigone, in which Antigone, one of the daughters of former King of Thebes, Oedipus, defies Creon, the current King of Thebes, who is trying to stop her from giving her brother Polynices a proper burial. She gives a stirring speech in which she tells him that she must obey her conscience rather than human law. She is not at all afraid of the death he threatens her with (and eventually carries out), but she is afraid of how her conscience will smite her if she does not do this.[5] Conrad Grebel and Anabaptists advocated civil disobedience to oppression.[6] Étienne de La Boétie's thought developed in his work Discours de la servitude volontaire ou le Contr'un (1552) was also taken up by many movements of civil disobedience, which drew from the concept of rebellion to voluntary servitude the foundation of its instrument of struggle. Étienne de La Boétie was one of the first to theorize and propose the strategy of non-cooperation, and thus a form of nonviolent disobedience, as a really effective weapon. In the lead-up to the Glorious Revolution in Britain—when the 1689 Bill of Rights was documented, the last Catholic monarch was deposed, and male and female joint-co-monarchs elevated—the English Midland Enlightenment developed a manner of voicing objection to a law viewed as illegitimate and then taking the consequences of the law. This was focused on the illegitimacy of laws claimed to be "divine" in origin, both the "divine rights of kings" and "divine rights of man", and the legitimacy of laws acknowledged to be made by human beings.[7][8][9][relevant?] Following the Peterloo massacre of 1819, the poet Percy Shelley wrote the political poem The Mask of Anarchy later that year, that begins with the images of what he thought to be the unjust forms of authority of his time—and then imagines the stirrings of a new form of social action. According to Ashton Nichols, it is perhaps the first modern statement of the principle of nonviolent protest.[10] A version was taken up by the author Henry David Thoreau in his essay Civil Disobedience, and later by Gandhi in his doctrine of Satyagraha.[10] Gandhi's Satyagraha was partially influenced and inspired by Shelley's nonviolence in protest and political action.[11] In particular, it is known that Gandhi often quoted Shelley's Masque of Anarchy to vast audiences during the campaign for a free India.[10][12] Thoreau's 1849 essay Civil Disobedience, originally titled "Resistance to Civil Government", has had a wide influence on many later practitioners of civil disobedience. The driving idea behind the essay is that citizens are morally responsible for their support of aggressors, even when such support is required by law. In the essay, Thoreau explained his reasons for having refused to pay taxes as an act of protest against slavery and against the Mexican–American War. He writes, If I devote myself to other pursuits and contemplations, I must first see, at least, that I do not pursue them sitting upon another man's shoulders. I must get off him first, that he may pursue his contemplations too. See what gross inconsistency is tolerated. I have heard some of my townsmen say, "I should like to have them order me out to help put down an insurrection of the slaves, or to march to Mexico;—see if I would go;" and yet these very men have each, directly by their allegiance, and so indirectly, at least, by their money, furnished a substitute. By the 1850s, a range of minority groups in the United States: African Americans, Jews, Seventh Day Baptists, Catholics, anti-prohibitionists, racial egalitarians, and others—employed civil disobedience to combat a range of legal measures and public practices that to them promoted ethnic, religious, and racial discrimination. Pro Public and typically peaceful resistance to political power remained an integral tactic in modern American minority rights politics.[13] In Ireland starting from 1879 the Irish "Land War" intensified when Irish nationalist leader Charles Stewart Parnell, in a speech in Ennis proposed that when dealing with tenants who take farms where another tenant was evicted, rather than resorting to violence, everyone in the locality should shun them. Following this Captain Charles Boycott, the land agent of an absentee landlord in County Mayo, Ireland, was subject to social ostracism organized by the Irish Land League in 1880. Boycott attempted to evict eleven tenants from his land. While Parnell's speech did not refer to land agents or landlords, the tactic was applied to Boycott when the alarm was raised about the evictions. Despite the short-term economic hardship to those undertaking this action, Boycott soon found himself isolated – his workers stopped work in the fields and stables, as well as in his house. Local businessmen stopped trading with him, and the local postman refused to deliver mail. The movement spread throughout Ireland and gave rise to the term to Boycott, and eventually led to legal reform and support for Irish independence.[14] Egypt saw a massive implementation on a nation-wide movement starting 1914 and peaking in 1919 as the Egyptian Revolution of 1919. This was then adopted by other native peoples who objected to British occupation from 1920 and on. This was not used with native laws that were more oppressive than the British occupation[specify], leading to problems for these countries today.[15] Zaghloul Pasha, considered the mastermind behind this massive civil disobedience, was a native middle-class, Azhar graduate, political activist, judge, parliamentary and ex-cabinet minister whose leadership brought Christian and Muslim communities together as well as women into the massive protests. Along with his companions of Wafd Party, who have achieved an independence of Egypt and a first constitution in 1923. Civil disobedience is one of the many ways people have revolted against what they deem to be unfair laws. It has been used in many nonviolent resistance movements in India (Mahatma Gandhi's campaigns for independence from the British Empire), in Czechoslovakia's Velvet Revolution, in early stages of the Bangladeshi independence movement against Pakistani colonialism and in East Germany to oust their Stalinist government.[16] In South Africa during the leftist campaign against the far-right Apartheid regime, in the American civil rights movement against Jim Crow laws, in the Singing Revolution to bring independence to the Baltic countries from the Soviet Union, and more recently with the 2003 Rose Revolution in Georgia, the 2004 Orange Revolution[17] and the 2013–2014 Euromaidan revolution in Ukraine, the 2016–2017 Candlelight Revolution in South Korea, and the 2020–2021 Belarusian protests, among many other various movements worldwide. Etymology Henry David Thoreau's classic essay Civil Disobedience inspired Martin Luther King Jr. and many other activists.Henry David Thoreau's 1849 essay "Resistance to Civil Government" was eventually renamed "Essay on Civil Disobedience". After his landmark lectures were published in 1866, the term began to appear in numerous sermons and lectures relating to slavery and the war in Mexico.[18][19][20][21] Thus, by the time Thoreau's lectures were first published under the title "Civil Disobedience", in 1866, four years after his death, the term had achieved fairly widespread usage. It has been argued that the term "civil disobedience" has always suffered from ambiguity and in modern times, become utterly debased. Marshall Cohen notes, "It has been used to describe everything from bringing a test-case in the federal courts to taking aim at a federal official. Indeed, for Vice President Spiro Agnew it has become a code-word describing the activities of muggers, arsonists, draft evaders, campaign hecklers, campus militants, anti-war demonstrators, juvenile delinquents and political assassins."[22] LeGrande writes that the formulation of a single all-encompassing definition of the term is extremely difficult, if not impossible. In reviewing the voluminous literature on the subject, the student of civil disobedience rapidly finds himself surrounded by a maze of semantical problems and grammatical niceties. Like Alice in Wonderland, he often finds that specific terminology has no more (or no less) meaning than the individual orator intends it to have. He encourages a distinction between lawful protest demonstration, nonviolent civil disobedience, and violent civil disobedience.[23] In a letter to P. K. Rao, dated 10 September 1935, Gandhi disputes that his idea of civil disobedience was derived from the writings of Thoreau:[24] The statement that I had derived my idea of Civil Disobedience from the writings of Thoreau is wrong. The resistance to authority in South Africa was well advanced before I got the essay ... When I saw the title of Thoreau's great essay, I began to use his phrase to explain our struggle to the English readers. But I found that even "Civil Disobedience" failed to convey the full meaning of the struggle. I therefore adopted the phrase "Civil Resistance." TheoriesIn seeking an active form of civil disobedience, one may choose to deliberately break certain laws, such as by forming a peaceful blockade or occupying a facility illegally,[25] though sometimes violence has been known to occur. Often there is an expectation to be attacked or even beaten by the authorities. Protesters often undergo training in advance on how to react to arrest or to attack. Civil disobedience is usually defined as pertaining to a citizen's relation to the state and its laws, as distinguished from a constitutional impasse, in which two public agencies, especially two equally sovereign branches of government, conflict. For instance, if the head of government of a country were to refuse to enforce a decision of that country's highest court, it would not be civil disobedience, since the head of government would act in his or her capacity as public official rather than private citizen.[26] This definition is disputed by Thoreau's political philosophy on the conscience vs. the collective. The person is the final judge of right and wrong. More than this, since only people act, only a person can act unjustly. When the government knocks on the door, it is a person in the form of a postman or tax collector whose hand hits the wood. Before Thoreau's imprisonment, when a confused taxman had wondered aloud about how to handle his refusal to pay, Thoreau had advised, "Resign". If a man chose to be an agent of injustice, then Thoreau insisted on confronting him with the fact that he was making a choice. He admits that government may express the will of the majority but it may also express nothing more than the will of elite politicians. Even a good form of government is "liable to be abused and perverted before the people can act through it". If a government did express the voice of most people, this would not compel the obedience of those who disagree with what is said. The majority may be powerful but it is not necessarily right.[27] In his 1971 book, A Theory of Justice, John Rawls described civil disobedience as "a public, non-violent, conscientious yet political act contrary to law usually done with the aim of bringing about change in the law or policies of the government".[28] Ronald Dworkin held that there are three types of civil disobedience: "Integrity-based" civil disobedience occurs when a citizen disobeys a law they feel is immoral, as in the case of abolitionists disobeying the fugitive slave laws by refusing to turn over escaped slaves to authorities."Justice-based" civil disobedience occurs when a citizen disobeys laws to lay claim to some right denied to them, as when Black people illegally protested during the civil rights movement."Policy-based" civil disobedience occurs when a person breaks the law to change a policy they believe is dangerously wrong.[29]Some theories of civil disobedience hold that civil disobedience is only justified against governmental entities. Brownlee argues that disobedience in opposition to the decisions of non-governmental agencies such as trade unions, banks, and private universities can be justified if it reflects "a larger challenge to the legal system that permits those decisions to be taken". The same principle, she argues, applies to breaches of law in protest against international organizations and foreign governments.[30] It is usually recognized that lawbreaking, if it is not done publicly, at least must be publicly announced to constitute civil disobedience. But Stephen Eilmann argues that if it is necessary to disobey rules that conflict with morality, we might ask why disobedience should take the form of public civil disobedience rather than simply covert lawbreaking. If a lawyer wishes to help a client overcome legal obstacles to securing their natural rights, he might, for instance, find that assisting in fabricating evidence or committing perjury is more effective than open disobedience. This assumes that common morality does not have a prohibition on deceit in such situations.[31] The Fully Informed Jury Association's publication "A Primer for Prospective Jurors" notes, "Think of the dilemma faced by German citizens when Hitler's secret police demanded to know if they were hiding a Jew in their house."[32] By this definition, civil disobedience could be traced back to the Book of Exodus, where Shiphrah and Puah refused a direct order of Pharaoh but misrepresented how they did it. (Exodus 1: 15–19)[33] Violent vs. nonviolentThere have been debates as to whether civil disobedience must necessarily be non-violent. Black's Law Dictionary includes nonviolence in its definition of civil disobedience. Christian Bay's encyclopedia article states that civil disobedience requires "carefully chosen and legitimate means", but holds that they do not have to be non-violent.[34] It has been argued that, while both civil disobedience and civil rebellion are justified by appeal to constitutional defects, rebellion is much more destructive; therefore, the defects justifying rebellion must be much more serious than those justifying disobedience, and if one cannot justify civil rebellion, then one cannot justify a civil disobedient's use of force and violence and refusal to submit to arrest. Civil disobedients' refraining from violence is also said to help preserve society's tolerance of civil disobedience.[35] The philosopher H. J. McCloskey argues that "if violent, intimidatory, coercive disobedience is more effective, it is, other things being equal, more justified than less effective, nonviolent disobedience."[36] In his best-selling Disobedience and Democracy: Nine Fallacies on Law and Order,[37] Howard Zinn takes a similar position; Zinn states that while the goals of civil disobedience are generally nonviolent, in the inevitable tension accompanying the transition from a violent world to a non-violent one, the choice of means will almost never be pure, and will involve such complexities that the simple distinction between violence and non-violence does not suffice as a guide ... the very acts with which we seek to do good cannot escape the imperfections of the world we are trying to change.[38] Zinn rejects any "easy and righteous dismissal of violence", noting that Thoreau, the popularizer of the term civil disobedience, approved of the armed insurrection of John Brown. He also notes that some major civil disobedience campaigns which have been classified as non-violent, such as the Birmingham campaign, have actually included elements of violence.[39][40] Revolutionary vs. non-revolutionaryNon-revolutionary civil disobedience is a simple disobedience of laws on the grounds that they are judged "wrong" by a person's conscience, or as part of an effort to render certain laws ineffective, to cause their repeal, or to exert pressure to get one's political wishes on some other issue. Revolutionary civil disobedience is more of an active attempt to overthrow a government (or to change cultural traditions, social customs or religious beliefs). Revolution does not have to be political, i.e. "cultural revolution", it simply implies sweeping and widespread change to a section of the social fabric.[41] Gandhi's acts have been described as revolutionary civil disobedience.[26] It has been claimed that the Hungarians under Ferenc Deák directed revolutionary civil disobedience against the Austrian government.[42] Thoreau also wrote of civil disobedience accomplishing "peaceable revolution".[43] Howard Zinn, Harvey Wheeler, and others have identified the right espoused in the US Declaration of Independence to "alter or abolish" an unjust government to be a principle of civil disobedience.[40][44] Collective vs. solitaryThe earliest recorded incidents of collective civil disobedience took place during the Roman Empire.[45] Unarmed Jews gathered in the streets to prevent the installation of pagan images in the Temple in Jerusalem.[46][original research?] In modern times, some activists who commit civil disobedience as a group collectively refuse to sign bail until certain demands are met, such as favourable bail conditions, or the release of all the activists. This is a form of jail solidarity.[47][page needed] There have also been many instances of solitary civil disobedience, such as that committed by Thoreau, but these sometimes go unnoticed. Thoreau, at the time of his arrest, was not yet a well-known author, and his arrest was not covered in any newspapers in the days, weeks and months after it happened. The tax collector who arrested him rose to higher political office, and Thoreau's essay was not published until after the end of the Mexican War.[48] ChoicesFurther information: Examples of civil disobedienceActionCivil disobedients have chosen a variety of different illegal acts. Hugo A. Bedau writes, There is a whole class of acts, undertaken in the name of civil disobedience, which, even if they were widely practiced, would in themselves constitute hardly more than a nuisance (e.g. trespassing at a nuclear-missile installation) ... Such acts are often just a harassment and, at least to the bystander, somewhat inane ... The remoteness of the connection between the disobedient act and the objectionable law lays such acts open to the charge of ineffectiveness and absurdity. Bedau also notes, though, that the very harmlessness of such entirely symbolic illegal protests toward public policy goals may serve a propaganda purpose.[42] Some civil disobedients, such as the proprietors of illegal medical cannabis dispensaries and Voice in the Wilderness, which brought medicine to Iraq without the permission of the US government, directly achieve a desired social goal (such as the provision of medication to the sick) while openly breaking the law. Julia Butterfly Hill lived in Luna, a 180-foot (55 m)-tall, 600-year-old California Redwood tree for 738 days, preventing its felling. In cases where the criminalized behaviour is pure speech, civil disobedience can consist simply of engaging in the forbidden speech. An example is WBAI's broadcasting of the bit "Filthy Words" from a George Carlin comedy album, which eventually led to the 1978 Supreme Court case of FCC v. Pacifica Foundation. Threatening government officials is another classic way of expressing defiance toward the government and unwillingness to stand for its policies. For example, Joseph Haas was arrested for allegedly sending an email to the Lebanon, New Hampshire, city councillors stating, "Wise up or die."[49] More generally, protesters of particular victimless crimes often see fit to openly commit that crime. Laws against public nudity, for instance, have been protested by going naked in public, and laws against cannabis consumption have been protested by openly possessing it and using it at cannabis rallies.[50] Some forms of civil disobedience, such as illegal boycotts, refusals to pay taxes, draft dodging, distributed denial-of-service attacks, and sit-ins, make it more difficult for a system to function. In this way, they might be considered coercive; coercive disobedience has the effect of exposing the enforcement of laws and policies, and it has even operated as an aesthetic strategy in contemporary art practice.[51] Brownlee notes that "although civil disobedients are constrained in their use of coercion by their conscientious aim to engage in moral dialogue, nevertheless they may find it necessary to employ limited coercion to get their issue onto the table".[30] The Plowshares organization temporarily closed GCSB Waihopai by padlocking the gates and using sickles to deflate one of the large domes covering two satellite dishes. Electronic civil disobedience can include web site defacements, redirects, denial-of-service attacks, information theft and data leaks, illegal web site parodies, virtual sit-ins, and virtual sabotage. It is distinct from other kinds of hacktivism in that the perpetrator openly reveals his identity. Virtual actions rarely succeed in completely shutting down their targets, but they often generate significant media attention.[52] Dilemma actions are designed to create a "response dilemma" for public authorities "by forcing them to either concede some public space to protesters or make themselves look absurd or heavy-handed by acting against the protest."[53] Compliance A police officer speaks with a demonstrator at a union picket, explaining that she will be arrested if she does not leave the street. The demonstrator was arrested moments later.Some disciplines of civil disobedience hold that the protester must submit to arrest and cooperate with the authorities. Others advocate falling limp or resisting arrest, especially when it will hinder the police from effectively responding to a mass protest. Many of the same decisions and principles that apply in other criminal investigations and arrests arise also in civil disobedience cases. For example, the suspect may need to decide whether to grant a consent search of his property, and whether to talk to police officers. It is generally agreed within the legal community,[54] and is often believed within the activist community, that a suspect's talking to criminal investigators can serve no useful purpose, and may be harmful. Some civil disobedients are compelled to respond to investigators' questions, sometimes by a misunderstanding of the legal ramifications or a fear of seeming rude.[55] Also, some civil disobedients seek to use the arrest as an opportunity to make an impression on the officers. Thoreau wrote, My civil neighbor, the tax-gatherer, is the very man I have to deal with—for it is, after all, with men and not with parchment that I quarrel—and he has voluntarily chosen to be an agent of the government. How shall he ever know well that he is and does as an officer of the government, or as a man, until he is obliged to consider whether he will treat me, his neighbor, for whom he has respect, as a neighbor and well-disposed man, or as a maniac and disturber of the peace, and see if he can get over this obstruction to his neighborliness without a ruder and more impetuous thought or speech corresponding with his action.[43] Some civil disobedients feel it is incumbent upon them to accept punishment because of their belief in the validity of the social contract, which is held to bind all to obey the laws that a government meeting certain standards of legitimacy has established, or else suffer the penalties set out in the law. Other civil disobedients who favour the existence of government still do not believe in the legitimacy of their particular government or do not believe in the legitimacy of a particular law it has enacted. Anarchistic civil disobedients do not believe in the legitimacy of any government, so see no need to accept punishment for a violation of criminal law. PleaAn important decision for civil disobedients is whether to plead guilty. There is much debate on this point, as some believe that it is a civil disobedient's duty to submit to the punishment prescribed by law, while others believe that defending oneself in court will increase the possibility of changing the unjust law.[56] It has also been argued that either choice is compatible with the spirit of civil disobedience. ACT UP's Civil Disobedience Training handbook states that a civil disobedient who pleads guilty is essentially stating, "Yes, I committed the act of which you accuse me. I don't deny it; in fact, I am proud of it. I feel I did the right thing by violating this particular law; I am guilty as charged", but that pleading not guilty sends a message of, "Guilt implies wrong-doing. I feel I have done no wrong. I may have violated some specific laws, but I am guilty of doing no wrong. I, therefore, plead not guilty." A plea of no contest is sometimes regarded as a compromise between the two.[57] One defendant accused of illegally protesting nuclear power, when asked to enter his plea, stated, "I plead for the beauty that surrounds us";[58] this is known as a "creative plea", and will usually be interpreted as a plea of not guilty.[59] When the Committee for Non-Violent Action sponsored a protest in August 1957, at the Camp Mercury nuclear test site near Las Vegas, Nevada, 13 of the protesters attempted to enter the test site knowing that they faced arrest. At an announced time, one by one they crossed a line and were immediately arrested. They were put on a bus and taken to the Nye County seat of Tonopah, Nevada, and arraigned for trial before the local Justice of the Peace, that afternoon. A civil rights attorney, Francis Heisler, had volunteered to defend the accused, advising them to plead nolo contendere rather than guilty or not guilty. They were found guilty and given suspended sentences, conditional on not reentering the test site.[60] Howard Zinn writes, There may be many times when protesters choose to go to jail, as a way of continuing their protest, as a way of reminding their countrymen of injustice. But that is different than the notion that they must go to jail as part of a rule connected with civil disobedience. The key point is that the spirit of protest should be maintained all the way, whether it is done by remaining in jail, or by evading it. To accept jail penitently as an accession to "the rules" is to switch suddenly to a spirit of subservience, to demean the seriousness of the protest ... In particular, the neo-conservative insistence on a guilty plea should be eliminated.[61] Sometimes the prosecution proposes a plea bargain to civil disobedients, as in the case of the Camden 28, in which the defendants were offered an opportunity to plead guilty to one misdemeanour count and receive no jail time.[62] In some mass arrest situations, the activists decide to use solidarity tactics to secure the same plea bargain for everyone.[59] But some activists have opted to enter a blind plea, pleading guilty without any plea agreement in place. Mahatma Gandhi pleaded guilty and told the court, "I am here to ... submit cheerfully to the highest penalty that can be inflicted upon me for what in law is a deliberate crime and what appears to me to be the highest duty of a citizen."[63] AllocutionSome civil disobedience defendants choose to make a defiant speech, or a speech explaining their actions, in allocution. In U.S. v. Burgos-Andujar, a defendant who was involved in a movement to stop military exercises by trespassing on US Navy property argued to the court in allocution that "the ones who are violating the greater law are the members of the Navy". As a result, the judge increased her sentence from 40 to 60 days. This action was upheld because, according to the US Court of Appeals for the First Circuit, her statement suggested a lack of remorse, an attempt to avoid responsibility for her actions, and even a likelihood of repeating her illegal actions.[64] Some of the other allocution speeches given by the protesters complained about mistreatment from government officials.[65] Tim DeChristopher gave an allocution statement to the court describing the US as "a place where the rule of law was created through acts of civil disobedience" and arguing, "Since those bedrock acts of civil disobedience by our founding fathers, the rule of law in this country has continued to grow closer to our shared higher moral code through the civil disobedience that drew attention to legalized injustice."[66] Legal implicationsSteven Barkan writes that if defendants plead not guilty, "they must decide whether their primary goal will be to win an acquittal and avoid imprisonment or a fine, or to use the proceedings as a forum to inform the jury and the public of the political circumstances surrounding the case and their reasons for breaking the law via civil disobedience." A technical defence may enhance the chances for acquittal but increase the possibility of additional proceedings and of reduced press coverage. During the Vietnam War era, the Chicago Eight used a political defence, but Benjamin Spock used a technical defence.[67] In countries such as the United States, whose laws guarantee the right to a jury trial but do not excuse lawbreaking for political purposes, some civil disobedients seek jury nullification. Over the years, this has been made more difficult by court decisions such as Sparf v. United States, which held that the judge need not inform jurors of their nullification prerogative, and United States v. Dougherty, which held that the judge need not allow defendants to openly seek jury nullification. Governments have generally not recognized the legitimacy of civil disobedience or viewed political objectives as an excuse for breaking the law. Specifically, the law usually distinguishes between criminal motive and criminal intent; the offender's motives or purposes may be admirable and praiseworthy, but his intent may still be criminal.[68] Hence the saying that "if there is any possible justification of civil disobedience it must come from outside the legal system."[69] One theory is that, while disobedience may be helpful, any great amount of it undermines the law by encouraging general disobedience which is neither conscientious nor of social benefit. Therefore, conscientious lawbreakers must be punished.[70] Michael Bayles argues that if a person violates a law to create a test case as to the constitutionality of a law, and then wins his case, then that act did not constitute civil disobedience.[71] It has also been argued that breaking the law for self-gratification, as in the case of a cannabis user who does not direct his act at securing the repeal of amendment of the law, is not civil disobedience.[72] Likewise, a protester who attempts to escape punishment by committing the crime covertly and avoiding attribution, or by denying having committed the crime, or by fleeing the jurisdiction, is generally not called a civil disobedient. Courts have distinguished between two types of civil disobedience: "Indirect civil disobedience involves violating a law which is not, itself, the object of protest, whereas direct civil disobedience involves protesting the existence of a particular law by breaking that law."[73] During the Vietnam War, courts typically refused to excuse the perpetrators of illegal protests from punishment on the basis of their challenging the legality of the Vietnam War; the courts ruled it was a political question.[74] The necessity defence has sometimes been used as a shadow defence by civil disobedients to deny guilt without denouncing their politically motivated acts, and to present their political beliefs in the courtroom.[75] Court cases such as United States v. Schoon have greatly curtailed the availability of the political necessity defence.[76] Likewise, when Carter Wentworth was charged for his role in the Clamshell Alliance's 1977 illegal occupation of the Seabrook Station Nuclear Power Plant, the judge instructed the jury to disregard his competing harms defence, and he was found guilty.[77] Fully Informed Jury Association activists have sometimes handed out educational leaflets inside courthouses despite admonitions not to; according to the association, many of them have escaped prosecution because "prosecutors have reasoned (correctly) that if they arrest fully informed jury leafleters, the leaflets will have to be given to the leafleter's own jury as evidence."[78] Along with giving the offender his just deserts, achieving crime control via incapacitation and deterrence is a major goal of criminal punishment.[79][80] Brownlee argues, "Bringing in deterrence at the level of justification detracts from the law's engagement in a moral dialogue with the offender as a rational person because it focuses attention on the threat of punishment and not the moral reasons to follow this law."[30] British judge Lord Hoffman writes, "In deciding whether or not to impose punishment, the most important consideration would be whether it would do more harm than good. This means that the objector has no right not to be punished. It is a matter for the state (including the judges) to decide on utilitarian grounds whether to do so or not."[81] Hoffman also asserted that while the "rules of the game" for protesters were to remain non-violent while breaking the law, the authorities must recognize that demonstrators are acting out of their conscience in pursuit of democracy. "When it comes to punishment, the court should take into account their personal convictions", he said.[82] See alsoAnti-establishment – Opposition to the conventional social, political, and economic principles of a societyAgorism – Social philosophy advocating a voluntary societyAstroturfing – Public relations tactic using fake grassroots movementsBillboard hacking – Illegal alteration of a billboardCivil resistance – Political action that relies on the use of non-violent methods by civil groupsCivilian-based defenseClimate disobedience – What people can do personally to help stop global warmingColour revolution – Political term associated with post-Soviet revolutionsConscientious objector – Person refusing military service on moral groundsCounterculture – Subculture whose values and norms of behavior deviate from those of mainstream societyCounter-economics – Economic theory and methodCulture jamming – Form of protest to subvert media cultureDemonstration – Collective action by people in favor of a causeDissent – Non-agreement or opposition to authorityDirect action – Method of activismDiversity of tactics – Social phenomenonEcoterrorism – Act of violence committed in support of environmental causesExtinction Rebellion – Environmental pressure groupGene Sharp – American political scientist (1928–2018)Grassroots – Movement based on local communitiesGrey market – Commodity trade outside of original producer's distribution channelHunt sabotage – Interference with hunting by animal rights activistsIndian independence movement – 1857–1947 movement to end British rule over IndiaInsubordination – Act of willfully disobeying one's superiorInternet activism – Form of activism on the internetMalicious compliance – Behaviour of intentionally inflicting harm by strictly following the orders of a superiorMass incidents in China – Large-scale incidents of civil disobedienceMinority influence – Form of social influenceNonconformism to the established Church of EnglandNon-conformists of the 1930s – Avantgarde movement during the inter-war period in FranceNonviolent resistance – Act of protest through nonviolent meansNonviolent revolution – Civil resistance to bring about the departure of governmentsOff-the-grid – Not being connected to public utilitiesProtest art – creative works that concern or are produced by activists and social movementsSatyagraha – Form of nonviolent resistance practised during British colonial rule in IndiaTree sitting – Occupying trees as a political protestUnderground culture – various alternative culturesUser revolt – Type of website-based social conflict The Voting Rights Act of 1965 is a landmark piece of federal legislation in the United States that prohibits racial discrimination in voting.[7][8] It was signed into law by President Lyndon B. Johnson during the height of the civil rights movement on August 6, 1965, and Congress later amended the Act five times to expand its protections.[7] Designed to enforce the voting rights guaranteed by the Fourteenth and Fifteenth Amendments to the United States Constitution, the Act sought to secure the right to vote for racial minorities throughout the country, especially in the South. According to the U.S. Department of Justice, the Act is considered to be the most effective piece of federal civil rights legislation ever enacted in the country.[9] It is also "one of the most far-reaching pieces of civil rights legislation in U.S. history."[10] The act contains numerous provisions that regulate elections. The act's "general provisions" provide nationwide protections for voting rights. Section 2 is a general provision that prohibits state and local government from imposing any voting rule that "results in the denial or abridgement of the right of any citizen to vote on account of race or color" or membership in a language minority group.[11] Other general provisions specifically outlaw literacy tests and similar devices that were historically used to disenfranchise racial minorities. The act also contains "special provisions" that apply to only certain jurisdictions. A core special provision is the Section 5 preclearance requirement, which prohibited certain jurisdictions from implementing any change affecting voting without first receiving confirmation from the U.S. attorney general or the U.S. District Court for D.C. that the change does not discriminate against protected minorities.[12] Another special provision requires jurisdictions containing significant language minority populations to provide bilingual ballots and other election materials. Section 5 and most other special provisions applied to jurisdictions encompassed by the "coverage formula" prescribed in Section 4(b). The coverage formula was originally designed to encompass jurisdictions that engaged in egregious voting discrimination in 1965, and Congress updated the formula in 1970 and 1975. In Shelby County v. Holder (2013), the U.S. Supreme Court struck down the coverage formula as unconstitutional, reasoning that it was obsolete.[13] The court did not strike down Section 5, but without a coverage formula, Section 5 is unenforceable.[14] The jurisdictions which had previously been covered by the coverage formula massively increased the rate of voter registration purges after the Shelby decision.[15] In 2021, the Brnovich v. Democratic National Committee Supreme Court ruling reinterpreted Section 2 of the Voting Rights Act of 1965, substantially weakening it.[16][11] The ruling interpreted the "totality of circumstances" language of Section 2 to mean that it does not generally prohibit voting rules that have disparate impact on the groups that it sought to protect, including a rule blocked under Section 5 before the Court inactivated that section in Shelby County v. Holder.[16][11] In particular, the ruling held that fears of election fraud could justify such rules, even without evidence that any such fraud had occurred in the past or that the new rule would make elections safer.[11] Research shows that the Act had successfully and massively increased voter turnout and voter registrations, in particular among black people.[17][18][19] The Act has also been linked to concrete outcomes, such as greater public goods provision (such as public education) for areas with higher black population shares, more members of Congress who vote for civil rights-related legislation, and greater Black representation in local offices.[20][21][22] BackgroundFurther information: Disenfranchisement after the Reconstruction eraAs initially ratified, the United States Constitution granted each state complete discretion to determine voter qualifications for its residents.[23][24]: 50  After the Civil War, the three Reconstruction Amendments were ratified and limited this discretion. The Thirteenth Amendment (1865) prohibits slavery "except as a punishment for crime"; the Fourteenth Amendment (1868) grants citizenship to anyone "born or naturalized in the United States" and guarantees every person due process and equal protection rights; and the Fifteenth Amendment (1870) provides that "[t]he right of citizens of the United States to vote shall not be denied or abridged by the United States or by any State on account of race, color, or previous condition of servitude." These Amendments also empower Congress to enforce their provisions through "appropriate legislation".[25] To enforce the Reconstruction Amendments, Congress passed the Enforcement Acts in the 1870s. The acts criminalized the obstruction of a citizen's voting rights and provided for federal supervision of the electoral process, including voter registration.[26]: 310  However, in 1875 the Supreme Court struck down parts of the legislation as unconstitutional in United States v. Cruikshank and United States v. Reese.[27]: 97  After the Reconstruction Era ended in 1877, enforcement of these laws became erratic, and in 1894, Congress repealed most of their provisions.[26]: 310  Southern states generally sought to disenfranchise racial minorities during and after Reconstruction. From 1868 to 1888, electoral fraud and violence throughout the South suppressed the African-American vote.[28] From 1888 to 1908, Southern states legalized disenfranchisement by enacting Jim Crow laws; they amended their constitutions and passed legislation to impose various voting restrictions, including literacy tests, poll taxes, property-ownership requirements, moral character tests, requirements that voter registration applicants interpret particular documents, and grandfather clauses that allowed otherwise-ineligible persons to vote if their grandfathers voted (which excluded many African Americans whose grandfathers had been slaves or otherwise ineligible).[26][28] During this period, the Supreme Court generally upheld efforts to discriminate against racial minorities. In Giles v. Harris (1903), the court held that regardless of the Fifteenth Amendment, the judiciary did not have the remedial power to force states to register racial minorities to vote.[27]: 100  refer to captionAlabama police in 1965 attack voting rights marchers on "Bloody Sunday", the first of the Selma to Montgomery marchesPrior to the enactment of the Voting Rights Act of 1965 there were several efforts to stop the disenfranchisement of black voters by Southern states,.[7] Besides the above-mentioned literacy tests and poll taxes other bureaucratic restrictions were used to deny them the right to vote. African Americans also "risked harassment, intimidation, economic reprisals, and physical violence when they tried to register or vote. As a result, very few African Americans were registered voters, and they had very little, if any, political power, either locally or nationally."[29] In the 1950s the Civil Rights Movement increased pressure on the federal government to protect the voting rights of racial minorities. In 1957, Congress passed the first civil rights legislation since Reconstruction: the Civil Rights Act of 1957. This legislation authorized the attorney general to sue for injunctive relief on behalf of persons whose Fifteenth Amendment rights were denied, created the Civil Rights Division within the Department of Justice to enforce civil rights through litigation, and created the Commission on Civil Rights to investigate voting rights deprivations. Further protections were enacted in the Civil Rights Act of 1960, which allowed federal courts to appoint referees to conduct voter registration in jurisdictions that engaged in voting discrimination against racial minorities.[9] Although these acts helped empower courts to remedy violations of federal voting rights, strict legal standards made it difficult for the Department of Justice to successfully pursue litigation. For example, to win a discrimination lawsuit against a state that maintained a literacy test, the department needed to prove that the rejected voter-registration applications of racial minorities were comparable to the accepted applications of whites. This involved comparing thousands of applications in each of the state's counties in a process that could last months. The department's efforts were further hampered by resistance from local election officials, who would claim to have misplaced the voter registration records of racial minorities, remove registered racial minorities from the electoral rolls, and resign so that voter registration ceased. Moreover, the department often needed to appeal lawsuits several times before the judiciary provided relief because many federal district court judges opposed racial minority suffrage. Thus, between 1957 and 1964, the African-American voter registration rate in the South increased only marginally even though the department litigated 71 voting rights lawsuits.[27]: 514  Efforts to stop the disfranchisement by the Southern states had achieved only modest success overall and in some areas had proved almost entirely ineffectual, because the "Department of Justice's efforts to eliminate discriminatory election practices by litigation on a case-by-case basis had been unsuccessful in opening up the registration process; as soon as one discriminatory practice or procedure was proven to be unconstitutional and enjoined, a new one would be substituted in its place and litigation would have to commence anew."[7] Congress responded to rampant discrimination against racial minorities in public accommodations and government services by passing the Civil Rights Act of 1964. The act included some voting rights protections; it required registrars to equally administer literacy tests in writing to each voter and to accept applications that contained minor errors, and it created a rebuttable presumption that persons with a sixth-grade education were sufficiently literate to vote.[24]: 97 [30][31] However, despite lobbying from civil rights leaders, the Act did not prohibit most forms of voting discrimination.[32]: 253  President Lyndon B. Johnson recognized this, and shortly after the 1964 elections in which Democrats gained overwhelming majorities in both chambers of Congress, he privately instructed Attorney General Nicholas Katzenbach to draft "the goddamndest, toughest voting rights act that you can".[24]: 48–50  However, Johnson did not publicly push for the legislation at the time; his advisers warned him of political costs for vigorously pursuing a voting rights bill so soon after Congress had passed the Civil Rights Act of 1964, and Johnson was concerned that championing voting rights would endanger his Great Society reforms by angering Southern Democrats in Congress.[24]: 47–48, 50–52  Following the 1964 elections, civil rights organizations such as the Southern Christian Leadership Conference (SCLC) and the Student Nonviolent Coordinating Committee (SNCC) pushed for federal action to protect the voting rights of racial minorities.[32]: 254–255  Their efforts culminated in protests in Alabama, particularly in the city of Selma, where County Sheriff Jim Clark's police force violently resisted African-American voter registration efforts. Speaking about the voting rights push in Selma, James Forman of SNCC said: "Our strategy, as usual, was to force the U.S. government to intervene in case there were arrests—and if they did not intervene, that inaction would once again prove the government was not on our side and thus intensify the development of a mass consciousness among blacks. Our slogan for this drive was 'One Man, One Vote.'"[32]: 255  In January 1965, Martin Luther King Jr., James Bevel,[33][34] and other civil rights leaders organized several peaceful demonstrations in Selma, which were violently attacked by police and white counter-protesters. Throughout January and February, these protests received national media coverage and drew attention to the issue of voting rights. King and other demonstrators were arrested during a march on February 1 for violating an anti-parade ordinance; this inspired similar marches in the following days, causing hundreds more to be arrested.[32]: 259–261  On February 4, civil rights leader Malcolm X gave a militant speech in Selma in which he said that many African Americans did not support King's nonviolent approach;[32]: 262  he later privately said that he wanted to frighten whites into supporting King.[24]: 69  The next day, King was released and a letter he wrote addressing voting rights, "Letter From A Selma Jail", appeared in The New York Times.[32]: 262  With increasing national attention focused on Selma and voting rights, President Johnson reversed his decision to delay voting rights legislation. On February 6, he announced he would send a proposal to Congress.[24]: 69  Johnson did not reveal the proposal's content or disclose when it would come before Congress.[32]: 264  On February 18 in Marion, Alabama, state troopers violently broke up a nighttime voting-rights march during which officer James Bonard Fowler shot and killed young African-American protester Jimmie Lee Jackson, who was unarmed and protecting his mother.[32]: 265 [35] Spurred by this event, and at the initiation of Bevel,[32]: 267 [33][34][36]: 81–86  on March 7 SCLC and SNCC began the first of the Selma to Montgomery marches, in which Selma residents intended to march to Alabama's capital, Montgomery, to highlight voting rights issues and present Governor George Wallace with their grievances. On the first march, demonstrators were stopped by state and county police on horseback at the Edmund Pettus Bridge near Selma. The police shot tear gas into the crowd and trampled protesters. Televised footage of the scene, which became known as "Bloody Sunday", generated outrage across the country.[27]: 515  A second march was held on March 9, which became known as "Turnaround Tuesday". That evening, three white Unitarian ministers who participated in the march were attacked on the street and beaten with clubs by four Ku Klux Klan members.[37] The worst injured was Reverend James Reeb from Boston, who died on Thursday, March 11.[38] In the wake of the events in Selma, President Johnson, addressing a televised joint session of Congress on March 15, called on legislators to enact expansive voting rights legislation. In his speech, he used the words "we shall overcome", adopting the rallying cry of the civil rights movement.[32]: 278 [39] The Voting Rights Act of 1965 was introduced in Congress two days later while civil rights leaders, now under the protection of federal troops, led a march of 25,000 people from Selma to Montgomery.[27]: 516 [32]: 279, 282  Legislative historyEfforts to eliminate discriminatory election practices by litigation on a case-by-case basis by the United States Department of Justice had been unsuccessful and existing federal anti-discrimination laws were not sufficient to overcome the resistance by state officials to enforcement of the 15th Amendment. Against this backdrop Congress came to the conclusion that a new comprehensive federal bill was necessary to break the grip of state disfranchisement.[7] The United States Supreme Court explained this in South Carolina v. Katzenbach (1966) with the following words: In recent years, Congress has repeatedly tried to cope with the problem by facilitating case-by-case litigation against voting discrimination. The Civil Rights Act of 1957 authorized the Attorney General to seek injunctions against public and private interference with the right to vote on racial grounds. Perfecting amendments in the Civil Rights Act of 1960 permitted the joinder of States as parties defendant, gave the Attorney General access to local voting records, and authorized courts to register voters in areas of systematic discrimination. Title I of the Civil Rights Act of 1964 expedited the hearing of voting cases before three-judge courts and outlawed some of the tactics used to disqualify Negroes from voting in federal elections. Despite the earnest efforts of the Justice Department and of many federal judges, these new laws have done little to cure the problem of voting discrimination. [...] The previous legislation has proved ineffective for a number of reasons. Voting suits are unusually onerous to prepare, sometimes requiring as many as 6,000 man-hours spent combing through registration records in preparation for trial. Litigation has been exceedingly slow, in part because of the ample opportunities for delay afforded voting officials and others involved in the proceedings. Even when favorable decisions have finally been obtained, some of the States affected have merely switched to discriminatory devices not covered by the federal decrees, or have enacted difficult new tests designed to prolong the existing disparity between white and Negro registration. Alternatively, certain local officials have defied and evaded court orders or have simply closed their registration offices to freeze the voting rolls. The provision of the 1960 law authorizing registration by federal officers has had little impact on local maladministration, because of its procedural complexities.[40] In South Carolina v. Katzenbach (1966) the Supreme Court also held that Congress had the power to pass the Voting Rights Act of 1965 under its Enforcement Powers stemming from the Fifteenth Amendment: Congress exercised its authority under the Fifteenth Amendment in an inventive manner when it enacted the Voting Rights Act of 1965. First: the measure prescribes remedies for voting discrimination which go into effect without any need for prior adjudication. This was clearly a legitimate response to the problem, for which there is ample precedent under other constitutional provisions. See Katzenbach v. McClung, 379 U. S. 294, 379 U. S. 302–304; United States v. Darby, 312 U. S. 100, 312 U. S. 120–121. Congress had found that case-by-case litigation was inadequate to combat widespread and persistent discrimination in voting, because of the inordinate amount of time and energy required to overcome the obstructionist tactics invariably encountered in these lawsuits. After enduring nearly a century of systematic resistance to the Fifteenth Amendment, Congress might well decide to shift the advantage of time and inertia from the perpetrators of the evil to its victims. [...] Second: the Act intentionally confines these remedies to a small number of States and political subdivisions which, in most instances, were familiar to Congress by name. This, too, was a permissible method of dealing with the problem. Congress had learned that substantial voting discrimination presently occurs in certain sections of the country, and it knew no way of accurately forecasting whether the evil might spread elsewhere in the future. In acceptable legislative fashion, Congress chose to limit its attention to the geographic areas where immediate action seemed necessary. See McGowan v. Maryland, 366 U. S. 420, 366 U. S. 427; Salsburg v. Maryland, 346 U. S. 545, 346 U. S. 550–554. The doctrine of the equality of States, invoked by South Carolina, does not bar this approach, for that doctrine applies only to the terms upon which States are admitted to the Union, and not to the remedies for local evils which have subsequently appeared. See Coyle v. Smith, 221 U. S. 559, and cases cited therein.[41] Original billrefer to captionUnited States President Lyndon B. Johnson, Martin Luther King Jr., and Rosa Parks at the signing of the Voting Rights Act on August 6, 1965SenateThe Voting Rights Act of 1965 was introduced in Congress on March 17, 1965, as S. 1564, and it was jointly sponsored by Senate majority leader Mike Mansfield (D-MT) and Senate minority leader Everett Dirksen (R-IL), both of whom had worked with Attorney General Katzenbach to draft the bill's language.[42] Although Democrats held two-thirds of the seats in both chambers of Congress after the 1964 Senate elections,[24]: 49  Johnson worried that Southern Democrats would filibuster the legislation because they had opposed other civil rights efforts. He enlisted Dirksen to help gain Republican support. Dirksen did not originally intend to support voting rights legislation so soon after supporting the Civil Rights Act of 1964, but he expressed willingness to accept "revolutionary" legislation after learning about the police violence against marchers in Selma on Bloody Sunday.[24]: 95–96  Given Dirksen's key role in helping Katzenbach draft the legislation, it became known informally as the "Dirksenbach" bill.[24]: 96  After Mansfield and Dirksen introduced the bill, 64 additional senators agreed to cosponsor it,[24]: 150  with a total 46 Democratic and 20 Republican cosponsors.[43] The bill contained several special provisions that targeted certain state and local governments: a "coverage formula" that determined which jurisdictions were subject to the Act's other special provisions ("covered jurisdictions"); a "preclearance" requirement that prohibited covered jurisdictions from implementing changes to their voting procedures without first receiving approval from the U.S. attorney general or the U.S. District Court for D.C. that the changes were not discriminatory; and the suspension of "tests or devices", such as literacy tests, in covered jurisdictions. The bill also authorized the assignment of federal examiners to register voters, and of federal observers to monitor elections, to covered jurisdictions that were found to have engaged in egregious discrimination. The bill set these special provisions to expire after five years.[26]: 319–320 [27]: 520, 524 [44]: 5–6  The scope of the coverage formula was a matter of contentious congressional debate. The coverage formula reached a jurisdiction if (1) the jurisdiction maintained a "test or device" on November 1, 1964, and (2) less than 50 percent of the jurisdiction's voting-age residents either were registered to vote on November 1, 1964, or cast a ballot in the November 1964 presidential election.[26]: 317  This formula reached few jurisdictions outside the Deep South. To appease legislators who felt that the bill unfairly targeted Southern jurisdictions, the bill included a general prohibition on racial discrimination in voting that applied nationwide.[45]: 1352  The bill also included provisions allowing a covered jurisdiction to "bail out" of coverage by proving in federal court that it had not used a "test or device" for a discriminatory purpose or with a discriminatory effect during the 5 years preceding its bailout request.[44]: 6  Additionally, the bill included a "bail in" provision under which federal courts could subject discriminatory non-covered jurisdictions to remedies contained in the special provisions.[46][47]: 2006–2007  The bill was first considered by the Senate Judiciary Committee, whose chair, Senator James Eastland (D-MS), opposed the legislation with several other Southern senators on the committee. To prevent the bill from dying in committee, Mansfield proposed a motion to require the Judiciary Committee to report the bill out of committee by April 9, which the Senate overwhelmingly passed by a vote of 67 to 13.[24]: 150 [43] During the committee's consideration of the bill, Senator Ted Kennedy (D-MA) led an effort to amend the bill to prohibit poll taxes. Although the Twenty-fourth Amendment—which banned the use of poll taxes in federal elections— was ratified a year earlier, Johnson's administration and the bill's sponsors did not include a provision in the voting rights bill banning poll taxes in state elections because they feared courts would strike down the legislation as unconstitutional.[27]: 521 [32]: 285  Additionally, by excluding poll taxes from the definition of "tests or devices", the coverage formula did not reach Texas or Arkansas, mitigating opposition from those two states' influential congressional delegations.[27]: 521  Nonetheless, with the support of liberal committee members, Kennedy's amendment to prohibit poll taxes passed by a 9–4 vote. In response, Dirksen offered an amendment that exempted from the coverage formula any state that had at least 60 percent of its eligible residents registered to vote or that had a voter turnout that surpassed the national average in the preceding presidential election. This amendment, which effectively exempted all states from coverage except Mississippi, passed during a committee meeting in which three liberal members were absent. Dirksen offered to drop the amendment if the poll tax ban were removed. Ultimately, the bill was reported out of committee on April 9 by a 12–4 vote without a recommendation.[24]: 152–153  On April 22, the full Senate started debating the bill. Dirksen spoke first on the bill's behalf, saying that "legislation is needed if the unequivocal mandate of the Fifteenth Amendment ... is to be enforced and made effective, and if the Declaration of Independence is to be made truly meaningful."[24]: 154  Senator Strom Thurmond (D-SC) retorted that the bill would lead to "despotism and tyranny", and Senator Sam Ervin (D-NC) argued that the bill was unconstitutional because it deprived states of their right under Article I, Section 2 of the Constitution to establish voter qualifications and because the bill's special provisions targeted only certain jurisdictions. On May 6, Ervin offered an amendment to abolish the coverage formula's automatic trigger and instead allow federal judges to appoint federal examiners to administer voter registration. This amendment overwhelmingly failed, with 42 Democrats and 22 Republicans voting against it.[24]: 154–156  After lengthy debate, Ted Kennedy's amendment to prohibit poll taxes also failed 49–45 on May 11.[43] However, the Senate agreed to include a provision authorizing the attorney general to sue any jurisdiction, covered or non-covered, to challenge its use of poll taxes.[32]: 156–157 [44]: 2  An amendment offered by Senator Robert F. Kennedy (D-NY) to enfranchise English-illiterate citizens who had attained at least a sixth-grade education in a non-English-speaking school also passed by 48–19. Southern legislators offered a series of amendments to weaken the bill, all of which failed.[24]: 159  On May 25, the Senate voted for cloture by a 70–30 vote, thus overcoming the threat of filibuster and limiting further debate on the bill.[48] On May 26, the Senate passed the bill by a 77–19 vote (Democrats 47–16, Republicans 30–2); only senators representing Southern states voted against it.[24]: 161 [49] House of Representatives"Remarks on the Signing of the Voting Rights Act of 1965"20:40Statement by United States President Johnson on August 6, 1965, about the Voting Rights Act of 1965"Remarks on the Signing of the Voting Rights Act of 1965"21:03Audio onlyProblems playing these files? See media help.Emanuel Celler (D-NY), Chair of the House Judiciary Committee, introduced the Voting Rights Act in the House of Representatives on March 19, 1965, as H.R. 6400.[43] The House Judiciary Committee was the first committee to consider the bill. The committee's ranking Republican, William McCulloch (R-OH), generally supported expanding voting rights, but he opposed both the poll tax ban and the coverage formula, and he led opposition to the bill in committee. The committee eventually approved the bill on May 12, but it did not file its committee report until June 1.[24]: 162  The bill included two amendments from subcommittee: a penalty for private persons who interfered with the right to vote and a prohibition of all poll taxes. The poll tax prohibition gained Speaker of the House John McCormack's support. The bill was next considered by the Rules Committee, whose chair, Howard W. Smith (D-VA), opposed the bill and delayed its consideration until June 24, when Celler initiated proceedings to have the bill discharged from committee.[43] Under pressure from the bill's proponents, Smith allowed the bill to be released a week later, and the full House started debating the bill on July 6.[24]: 163  To defeat the Voting Rights Act, McCulloch introduced an alternative bill, H.R. 7896. It would have allowed the attorney general to appoint federal registrars after receiving 25 serious complaints of discrimination against a jurisdiction, and it would have imposed a nationwide ban on literacy tests for persons who could prove they attained a sixth-grade education. McCulloch's bill was co-sponsored by House minority leader Gerald Ford (R-MI) and supported by Southern Democrats as an alternative to the Voting Rights Act.[24]: 162–164  The Johnson administration viewed H.R. 7896 as a serious threat to passing the Voting Rights Act. However, support for H.R. 7896 dissipated after William M. Tuck (D-VA) publicly said he preferred H.R. 7896 because the Voting Rights Act would legitimately ensure that African Americans could vote. His statement alienated most supporters of H.R. 7896, and the bill failed on the House floor by a 171–248 vote on July 9.[50] Later that night, the House passed the Voting Rights Act by a 333–85 vote (Democrats 221–61, Republicans 112–24).[24]: 163–165 [43][51] Conference committeeThe chambers appointed a conference committee to resolve differences between the House and Senate versions of the bill. A major contention concerned the poll tax provisions; the Senate version allowed the attorney general to sue states that used poll taxes to discriminate, while the House version outright banned all poll taxes. Initially, the committee members were stalemated. To help broker a compromise, Attorney General Katzenbach drafted legislative language explicitly asserting that poll taxes were unconstitutional and instructed the Department of Justice to sue the states that maintained poll taxes. To assuage concerns of liberal committee members that this provision was not strong enough, Katzenbach enlisted the help of Martin Luther King Jr., who gave his support to the compromise. King's endorsement ended the stalemate, and on July 29, the conference committee reported its version out of committee.[24]: 166–167  The House approved this conference report version of the bill on August 3 by a 328–74 vote (Democrats 217–54, Republicans 111–20),[52] and the Senate passed it on August 4 by a 79–18 vote (Democrats 49–17, Republicans 30–1).[24]: 167 [53][54] On August 6, President Johnson signed the Act into law with King, Rosa Parks, John Lewis, and other civil rights leaders in attendance at the signing ceremony.[24]: 168  AmendmentsMain article: Amendments to the Voting Rights Act of 1965refer to captionUnited States President George W. Bush signs amendments to the Act in July 2006Congress enacted major amendments to the Act in 1970, 1975, 1982, 1992, and 2006. Each amendment coincided with an impending expiration of some or all of the Act's special provisions. Originally set to expire by 1970, Congress repeatedly reauthorized the special provisions in recognition of continuing voting discrimination.[24]: 209–210 [44]: 6–8  Congress extended the coverage formula and special provisions tied to it, such as the Section 5 preclearance requirement, for five years in 1970, seven years in 1975, and 25 years in both 1982 and 2006. In 1970 and 1975, Congress also expanded the reach of the coverage formula by supplementing it with new 1968 and 1972 trigger dates. Coverage was further enlarged in 1975 when Congress expanded the meaning of "tests or devices" to encompass any jurisdiction that provided English-only election information, such as ballots, if the jurisdiction had a single language minority group that constituted more than five percent of the jurisdiction's voting-age citizens. These expansions brought numerous jurisdictions into coverage, including many outside of the South.[55] To ease the burdens of the reauthorized special provisions, Congress liberalized the bailout procedure in 1982 by allowing jurisdictions to escape coverage by complying with the Act and affirmatively acting to expand minority political participation.[27]: 523  In addition to reauthorizing the original special provisions and expanding coverage, Congress amended and added several other provisions to the Act. For instance, Congress expanded the original ban on "tests or devices" to apply nationwide in 1970, and in 1975, Congress made the ban permanent.[44]: 6–9  Separately, in 1975 Congress expanded the Act's scope to protect language minorities from voting discrimination. Congress defined "language minority" to mean "persons who are American Indian, Asian American, Alaskan Natives or of Spanish heritage."[56] Congress amended various provisions, such as the preclearance requirement and Section 2's general prohibition of discriminatory voting laws, to prohibit discrimination against language minorities.[57]: 199  Congress also enacted a bilingual election requirement in Section 203, which requires election officials in certain jurisdictions with large numbers of English-illiterate language minorities to provide ballots and voting information in the language of the language minority group. Originally set to expire after 10 years, Congress reauthorized Section 203 in 1982 for seven years, expanded and reauthorized it in 1992 for 15 years, and reauthorized it in 2006 for 25 years.[58]: 19–21, 25, 49  The bilingual election requirements have remained controversial, with proponents arguing that bilingual assistance is necessary to enable recently naturalized citizens to vote and opponents arguing that the bilingual election requirements constitute costly unfunded mandates.[58]: 26  Several of the amendments responded to judicial rulings with which Congress disagreed. In 1982, Congress amended the Act to overturn the Supreme Court case Mobile v. Bolden (1980), which held that the general prohibition of voting discrimination prescribed in Section 2 prohibited only purposeful discrimination. Congress responded by expanding Section 2 to explicitly ban any voting practice that had a discriminatory effect, regardless of whether the practice was enacted or operated for a discriminatory purpose. The creation of this "results test" shifted the majority of vote dilution litigation brought under the Act from preclearance lawsuits to Section 2 lawsuits.[27]: 644–645  In 2006, Congress amended the Act to overturn two Supreme Court cases: Reno v. Bossier Parish School Board (2000),[59] which interpreted the Section 5 preclearance requirement to prohibit only voting changes that were enacted or maintained for a "retrogressive" discriminatory purpose instead of any discriminatory purpose, and Georgia v. Ashcroft (2003),[60] which established a broader test for determining whether a redistricting plan had an impermissible effect under Section 5 than assessing only whether a minority group could elect its preferred candidates.[61]: 207–208  Since the Supreme Court struck down the coverage formula as unconstitutional in Shelby County v. Holder (2013), several bills have been introduced in Congress to create a new coverage formula and amend various other provisions; none of these bills have passed.[62][63][64] Provisionsrefer to captionThe first page of the Voting Rights Act of 1965The act contains two types of provisions: "general provisions", which apply nationwide, and "special provisions", which apply to only certain states and local governments.[65]: 1  "The Voting Rights Act was aimed at the subtle, as well as the obvious, state regulations which have the effect of denying citizens their right to vote because of their race. Moreover, compatible with the decisions of this Court, the Act gives a broad interpretation to the right to vote, recognizing that voting includes "all action necessary to make a vote effective." 79 Stat. 445, 42 U.S.C. § 19731(c)(1) (1969 ed., Supp. I). See Reynolds v. Sims, 377 U. S. 533, 377 U. S. 555 (1964)."[66] Most provisions are designed to protect the voting rights of racial and language minorities. The term "language minority" means "persons who are American Indian, Asian American, Alaskan Natives or of Spanish heritage."[56] The act's provisions have been colored by numerous judicial interpretations and congressional amendments. General provisionsGeneral prohibition of discriminatory voting lawsSection 2 prohibits any jurisdiction from implementing a "voting qualification or prerequisite to voting, or standard, practice, or procedure ... in a manner which results in a denial or abridgement of the right ... to vote on account of race," color, or language minority status.[58]: 37 [67] Section 2 of the law contains two separate protections against voter discrimination for laws which, in contrast to Section 5 of the law, are already implemented.[68][69] The first protection is a prohibition of intentional discrimination based on race or color in voting. The second protection is a prohibition of election practices that result in the denial or abridgment of the right to vote based on race or color.[68][69][70][71] If the violation of the second protection is intentional, then this violation is also a violation of the Fifteenth Amendment.[70] The Supreme Court has allowed private plaintiffs to sue to enforce these prohibitions.[72]: 138 [73] In Mobile v. Bolden (1980), the Supreme Court held that as originally enacted in 1965, Section 2 simply restated the Fifteenth Amendment and thus prohibited only those voting laws that were intentionally enacted or maintained for a discriminatory purpose.[74]: 60–61 [75][68][7][76] In 1982, Congress amended Section 2 to create a "results" test,[77] which prohibits any voting law that has a discriminatory effect irrespective of whether the law was intentionally enacted or maintained for a discriminatory purpose.[78][79]: 3 [68][7][76] The 1982 amendments stipulated that the results test does not guarantee protected minorities a right to proportional representation.[80] In Thornburg v. Gingles (1986) the United States Supreme Court explained with respect to the 1982 amendment for section 2 that the "essence of a Section 2 claim is that a certain electoral law, practice, or structure interacts with social and historical conditions to cause an inequality in the opportunities enjoyed by black and white voters to elect their preferred representatives."[81] The United States Department of Justice declared that section 2 is not only a permanent and nationwide-applying prohibition against discrimination in voting to any voting standard, practice, or procedure that results in the denial or abridgement of the right of any citizen to vote on account of race, color, or membership in a language minority group, but also a prohibition for state and local officials to adopt or maintain voting laws or procedures that purposefully discriminate on the basis of race, color, or membership in a language minority group.[81] The United States Supreme Court expressed its views regarding Section 2 and its amendment from 1982 in Chisom v. Roemer (1991).[82] Under the amended statute, proof of intent is no longer required to prove a § 2 violation. Now plaintiffs can prevail under § 2 by demonstrating that a challenged election practice has resulted in the denial or abridgement of the right to vote based on color or race. Congress not only incorporated the results test in the paragraph that formerly constituted the entire § 2, but also designated that paragraph as subsection (a) and added a new subsection (b) to make clear that an application of the results test requires an inquiry into "the totality of the circumstances." Section 2(a) adopts a results test, thus providing that proof of discriminatory intent is no longer necessary to establish any violation of the section. Section 2(b) provides guidance about how the results test is to be applied.[83] There is a statutory framework to determine whether a jurisdiction's election law violates the general prohibition from Section 2 in its amended form:[84] Section 2 prohibits voting practices that “result[] in a denial or abridgment of the right * * * to vote on account of race or color [or language-minority status],” and it states that such a result “is established” if a jurisdiction’s “political processes * * * are not equally open” to members of such a group “in that [they] have less opportunity * * * to participate in the political process and to elect representatives of their choice.” 52 U.S.C. 10301. [...] Subsection (b) states in relevant part: A violation of subsection (a) is established if, based on the totality of circumstances, it is shown that the political processes leading to nomination or election in the State or political subdivision are not equally open to participation by members of a class of citizens protected by subsection (a) in that its members have less opportunity than other members of the electorate to participate in the political process and to elect representatives of their choice.[85][86] The Office of the Arizona Attorney general stated with respect to the framework to determine whether a jurisdiction's election law violates the general prohibition from Section 2 in its amended form and the reason for the adoption of Section 2 in its amended form: To establish a violation of amended Section 2, the plaintiff must prove,“based on the totality of circumstances,” that the State’s “political processes” are “not equally open to participation by members” of a protected class, “in that its members have less opportunity than other members of the electorate to participate in the political process and to elect representatives of their choice.” § 10301(b). That is the “result” that amended Section 2 prohibits: “less opportunity than other members of the electorate,” viewing the State’s “political processes” as a whole. The new language was crafted as a compromise designed to eliminate the need for direct evidence of discriminatory intent, which is often difficult to obtain, but without embracing an unqualified “disparate impact” test that would invalidate many legitimate voting procedures. S. REP. NO. 97–417, at 28–29, 31–32, 99 (1982)[87][86] In Brnovich v. Democratic National Committee (2021) the United States Supreme Court introduced the means to review Section 2 challenges.[88][89] The slip opinion stated in its Syllabus section in this regard that "The Court declines in these cases to announce a test to govern all VRA [Section 2] challenges to rules that specify the time, place, or manner for casting ballots. It is sufficient for present purposes to identify certain guideposts that lead to the Court's decision in these cases."[90] The Court laid out these guideposts used to evaluate the state regulations in context of Section 2, which included: the size of the burden created by the rule, the degree which the rule deviates from past practices, the size of the racial imbalance, and the overall level of opportunity afforded voters in considering all election rules.[91][89][71] When determining whether a jurisdiction's election law violates the general prohibition from Section 2 of the VRA, courts have relied on factors enumerated in the Senate Judiciary Committee report associated with the 1982 amendments ("Senate Factors"), including:[81] The history of official discrimination in the jurisdiction that affects the right to vote;The degree to which voting in the jurisdiction is racially polarized;The extent of the jurisdiction's use of majority vote requirements, unusually large electoral districts, prohibitions on bullet voting, and other devices that tend to enhance the opportunity for voting discrimination;Whether minority candidates are denied access to the jurisdiction's candidate slating processes, if any;The extent to which the jurisdiction's minorities are discriminated against in socioeconomic areas, such as education, employment, and health;Whether overt or subtle racial appeals in campaigns exist;The extent to which minority candidates have won elections;The degree that elected officials are unresponsive to the concerns of the minority group; andWhether the policy justification for the challenged law is tenuous.The report indicates not all or a majority of these factors need to exist for an electoral device to result in discrimination, and it also indicates that this list is not exhaustive, allowing courts to consider additional evidence at their discretion.[75][80]: 344 [92]: 28–29  No right is more precious in a free country than that of having a voice in the election of those who make the laws under which, as good citizens, we must live. Other rights, even the most basic, are illusory if the right to vote is undermined. Our Constitution leaves no room for classification of people in a way that unnecessarily abridges this right. — Justice Black on the right to vote as the foundation of democracy in Wesberry v. Sanders (1964).[93]Section 2 prohibits two types of discrimination: "vote denial", in which a person is denied the opportunity to cast a ballot or to have their vote properly counted, and "vote dilution",[94][95]: 2–6  in which the strength or effectiveness of a person's vote is diminished.[96]: 691–692  Most Section 2 litigation has concerned vote dilution, especially claims that a jurisdiction's redistricting plan or use of at-large/multimember elections prevents minority voters from casting sufficient votes to elect their preferred candidates.[96]: 708–709  An at-large election can dilute the votes cast by minority voters by allowing a cohesive majority group to win every legislative seat in the jurisdiction.[97]: 221  Redistricting plans can be gerrymandered to dilute votes cast by minorities by "packing" high numbers of minority voters into a small number of districts or "cracking" minority groups by placing small numbers of minority voters into a large number of districts.[98] In Thornburg v. Gingles (1986), the Supreme Court used the term "vote dilution through submergence" to describe claims that a jurisdiction's use of an at-large/multimember election system or gerrymandered redistricting plan diluted minority votes, and it established a legal framework for assessing such claims under Section 2.[a] Under the Gingles test, plaintiffs must show the existence of three preconditions: The racial or language minority group "is sufficiently numerous and compact to form a majority in a single-member district";The minority group is "politically cohesive" (meaning its members tend to vote similarly); andThe "majority votes sufficiently as a bloc to enable it ... usually to defeat the minority's preferred candidate."[100]: 50–51 The first precondition is known as the "compactness" requirement and concerns whether a majority-minority district can be created. The second and third preconditions are collectively known as the "racially polarized voting" or "racial bloc voting" requirement, and they concern whether the voting patterns of the different racial groups are different from each other. If a plaintiff proves these preconditions exist, then the plaintiff must additionally show, using the remaining Senate Factors and other evidence, that under the "totality of the circumstances", the jurisdiction's redistricting plan or use of at-large or multimember elections diminishes the ability of the minority group to elect candidates of its choice.[80]: 344–345  Subsequent litigation further defined the contours of these "vote dilution through submergence" claims. In Bartlett v. Strickland (2009),[101] the Supreme Court held that the first Gingles precondition can be satisfied only if a district can be drawn in which the minority group comprises a majority of voting-age citizens. This means that plaintiffs cannot succeed on a submergence claim in jurisdictions where the size of the minority group, despite not being large enough to comprise a majority in a district, is large enough for its members to elect their preferred candidates with the help of "crossover" votes from some members of the majority group.[102][103]: A2  In contrast, the Supreme Court has not addressed whether different protected minority groups can be aggregated to satisfy the Gingles preconditions as a coalition, and lower courts have split on the issue.[b] The Supreme Court provided additional guidance on the "totality of the circumstances" test in Johnson v. De Grandy (1994).[99] The court emphasized that the existence of the three Gingles preconditions may be insufficient to prove liability for vote dilution through submergence if other factors weigh against such a determination, especially in lawsuits challenging redistricting plans. In particular, the court held that even where the three Gingles preconditions are satisfied, a jurisdiction is unlikely to be liable for vote dilution if its redistricting plan contains a number of majority-minority districts that is proportional to the minority group's population size. The decision thus clarified that Section 2 does not require jurisdictions to maximize the number of majority-minority districts.[109] The opinion also distinguished the proportionality of majority-minority districts, which allows minorities to have a proportional opportunity to elect their candidates of choice, from the proportionality of election results, which Section 2 explicitly does not guarantee to minorities.[99]: 1013–1014  An issue regarding the third Gingles precondition remains unresolved. In Gingles, the Supreme Court split as to whether plaintiffs must prove that the majority racial group votes as a bloc specifically because its members are motivated to vote based on racial considerations and not other considerations that may overlap with race, such as party affiliation. A plurality of justices said that requiring such proof would violate Congress's intent to make Section 2 a "results" test, but Justice White maintained that the proof was necessary to show that an electoral scheme results in racial discrimination.[110]: 555–557  Since Gingles, lower courts have split on the issue.[c] The right to vote freely for the candidate of one's choice is of the essence of a democratic society, and any restrictions on that right strike at the heart of representative government. And the right of suffrage can be denied by a debasement or dilution of the weight of a citizen's vote just as effectively as by wholly prohibiting the free exercise of the franchise. [...] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. Especially since the right to exercise the franchise in a free and unimpaired manner is preservative of other basic civil and political rights, any alleged infringement of the right of citizens to vote must be carefully and meticulously scrutinized. — Chief Justice Earl Warren on the right to vote as the foundation of democracy in Reynolds v. Sims (1964).[114]Although most Section 2 litigation has involved claims of vote dilution through submergence,[96]: 708–709  courts also have addressed other types of vote dilution under this provision. In Holder v. Hall (1994),[115] the Supreme Court held that claims that minority votes are diluted by the small size of a governing body, such as a one-person county commission, may not be brought under Section 2. A plurality of the court reasoned that no uniform, non-dilutive "benchmark" size for a governing body exists, making relief under Section 2 impossible.[116] Another type of vote dilution may result from a jurisdiction's requirement that a candidate be elected by a majority vote. A majority-vote requirement may cause a minority group's candidate of choice, who would have won the election with a simple plurality of votes, to lose after a majority of voters unite behind another candidate in a runoff election. The Supreme Court has not addressed whether such claims may be brought under Section 2, and lower courts have reached different conclusions on the issue.[d] In addition to claims of vote dilution, courts have considered vote denial claims brought under Section 2. The Supreme Court, in Richardson v. Ramirez (1974),[119] held that felony disenfranchisement laws cannot violate Section 2 because, among other reasons, Section 2 of the Fourteenth Amendment permits such laws.[27]: 756–757  A federal district court in Mississippi held that a "dual registration" system that requires a person to register to vote separately for state elections and local elections may violate Section 2 if the system has a racially disparate impact in light of the Senate Factors.[27]: 754 [120] Starting in 2013, lower federal courts began to consider various challenges to voter ID laws brought under Section 2.[121] Specific prohibitionsThe act contains several specific prohibitions on conduct that may interfere with a person's ability to cast an effective vote. One of these prohibitions is prescribed in Section 201, which prohibits any jurisdiction from requiring a person to comply with any "test or device" to register to vote or cast a ballot. The term "test or device" is defined as literacy tests, educational or knowledge requirements, proof of good moral character, and requirements that a person be vouched for when voting.[122] Before the Act's enactment, these devices were the primary tools used by jurisdictions to prevent racial minorities from voting.[123] Originally, the Act suspended tests or devices temporarily in jurisdictions covered by the Section 4(b) coverage formula, but Congress subsequently expanded the prohibition to the entire country and made it permanent.[44]: 6–9  Relatedly, Section 202 prohibits jurisdictions from imposing any "durational residency requirement" that requires persons to have lived in the jurisdiction for more than 30 days before being eligible to vote in a presidential election.[124]: 353  Several further protections for voters are contained in Section 11. Section 11(a) prohibits any person acting under color of law from refusing or failing to allow a qualified person to vote or to count a qualified voter's ballot. Similarly, Section 11(b) prohibits any person from intimidating, harassing, or coercing another person for voting or attempting to vote.[58] Two provisions in Section 11 address voter fraud: Section 11(c) prohibits people from knowingly submitting a false voter registration application to vote in a federal election, and Section 11(e) prohibits voting twice in a federal election.[125][126]: 360  Finally, under Section 208, a jurisdiction may not prevent anyone who is English-illiterate or has a disability from being accompanied into the ballot box by an assistant of the person's choice. The only exceptions are that the assistant may not be an agent of the person's employer or union.[57]: 221  Bail-inSection 3(c) contains a "bail-in" or "pocket trigger" process by which jurisdictions that fall outside the coverage formula of Section 4(b) may become subject to preclearance. Under this provision, if a jurisdiction has racially discriminated against voters in violation of the Fourteenth or Fifteenth Amendments, a court may order the jurisdiction to have future changes to its election laws preapproved by the federal government.[47]: 2006–2007  Because courts have interpreted the Fourteenth and Fifteenth Amendments to prohibit only intentional discrimination, a court may bail in a jurisdiction only if the plaintiff proves that the jurisdiction enacted or operated a voting practice to purposely discriminate.[47]: 2009  Section 3(c) contains its own preclearance language and differs from Section 5 preclearance in several ways. Unlike Section 5 preclearance, which applies to a covered jurisdiction until such time as the jurisdiction may bail out of coverage under Section 4(a), bailed-in jurisdictions remain subject to preclearance for as long as the court orders. Moreover, the court may require the jurisdiction to preclear only particular types of voting changes. For example, the bail-in of New Mexico in 1984 applied for 10 years and required preclearance of only redistricting plans. This differs from Section 5 preclearance, which requires a covered jurisdiction to preclear all of its voting changes.[47]: 2009–2010 [127] During the Act's early history, Section 3(c) was little used; no jurisdictions were bailed in until 1975. Between 1975 and 2013, 18 jurisdictions were bailed in, including 16 local governments and the states of Arkansas and New Mexico.[128]: 1a–2a  Although the Supreme Court held the Section 4(b) coverage formula unconstitutional in Shelby County v. Holder (2013), it did not hold Section 3(c) unconstitutional. Therefore, jurisdictions may continue to be bailed-in and subjected to Section 3(c) preclearance.[13][129] In the months following Shelby County, courts began to consider requests by the attorney general and other plaintiffs to bail in the states of Texas and North Carolina,[130] and in January 2014 a federal court bailed in Evergreen, Alabama.[131] A more narrow bail-in process pertaining to federal observer certification is prescribed in Section 3(a). Under this provision, a federal court may certify a non-covered jurisdiction to receive federal observers if the court determines that the jurisdiction violated the voting rights guaranteed by the Fourteenth or Fifteenth Amendments. Jurisdictions certified to receive federal observers under Section 3(a) are not subject to preclearance.[132]: 236–237  Special provisionsSee also: List of jurisdictions subject to the special provisions of the Voting Rights Act of 1965Coverage formulaMap depicting states and counties encompassed by the act's coverage formula in January 2008 (excluding bailed-out jurisdictions)States and counties encompassed by the Act's coverage formula in January 2008 (excluding bailed-out jurisdictions). Several counties subsequently bailed out,[55] but the majority of the map accurately depicts covered jurisdictions before the Supreme Court's decision in Shelby County v. Holder (2013), which declared the coverage formula unconstitutional.Section 4(b) contains a "coverage formula" that determines which states and local governments may be subjected to the Act's other special provisions (except for the Section 203(c) bilingual election requirements, which fall under a different formula). Congress intended for the coverage formula to encompass the most pervasively discriminatory jurisdictions. A jurisdiction is covered by the formula if: As of November 1, 1964, 1968, or 1972, the jurisdiction used a "test or device" to restrict the opportunity to register and vote; andLess than half of the jurisdiction's eligible citizens were registered to vote on November 1, 1964, 1968, or 1972; or less than half of eligible citizens voted in the presidential election of November 1964, 1968, or 1972.As originally enacted, the coverage formula contained only November 1964 triggering dates; subsequent revisions to the law supplemented it with the additional triggering dates of November 1968 and November 1972, which brought more jurisdictions into coverage.[55] For purposes of the coverage formula, the term "test or device" includes the same four devices prohibited nationally by Section 201—literacy tests, educational or knowledge requirements, proof of good moral character, and requirements that a person be vouched for when voting—and one further device defined in Section 4(f)(3): in jurisdictions where more than five percent of the citizen voting age population are members of a single language minority group, any practice or requirement by which registration or election materials are provided only in English. The types of jurisdictions that the coverage formula applies to include states and "political subdivisions" of states.[57]: 207–208  Section 14(c)(2) defines "political subdivision" to mean any county, parish, or "other subdivision of a State which conducts registration for voting."[133] As Congress added new triggering dates to the coverage formula, new jurisdictions were brought into coverage. The 1965 coverage formula included the whole of Alabama, Alaska, Georgia, Louisiana, Mississippi, South Carolina, and Virginia; and some subdivisions (mostly counties) in Arizona, Hawaii, Idaho, and North Carolina.[55] The 1968 coverage resulted in the partial coverage of Alaska, Arizona, California, Connecticut, Idaho, Maine, Massachusetts, New Hampshire, New York, and Wyoming. Connecticut, Idaho, Maine, Massachusetts, and Wyoming filed successful "bailout" lawsuits, as also provided by section 4.[55] The 1972 coverage covered the whole of Alaska, Arizona, and Texas, and parts of California, Florida, Michigan, New York, North Carolina, and South Dakota.[55] The special provisions of the Act were initially due to expire in 1970, and Congress renewed them for another five years. In 1975, the Act's special provisions were extended for another seven years. In 1982, the coverage formula was extended again, this time for 25 years, but no changes were made to the coverage formula, and in 2006, the coverage formula was again extended for 25 years.[55] Throughout its history, the coverage formula remained controversial because it singled out certain jurisdictions for scrutiny, most of which were in the Deep South. In Shelby County v. Holder (2013), the Supreme Court declared the coverage formula unconstitutional because the criteria used were outdated and thus violated principles of equal state sovereignty and federalism.[13][134][135] The other special provisions that are dependent on the coverage formula, such as the Section 5 preclearance requirement, remain valid law. However, without a valid coverage formula, these provisions are unenforceable.[14][136] Preclearance requirementSection 5[137] requires that covered jurisdictions receive federal approval, known as "preclearance", before implementing changes to their election laws. A covered jurisdiction has the burden of proving that the change does not have the purpose or effect of discriminating on the basis of race or language minority status; if the jurisdiction fails to meet this burden, the federal government will deny preclearance and the jurisdiction's change will not go into effect. The Supreme Court broadly interpreted Section 5's scope in Allen v. State Board of Election (1969),[138] holding that any change in a jurisdiction's voting practices, even if minor, must be submitted for preclearance.[139] The court also held that if a jurisdiction fails to have its voting change precleared, private plaintiffs may sue the jurisdiction in the plaintiff's local district court before a three-judge panel.[e] In these Section 5 "enforcement actions", a court considers whether the jurisdiction made a covered voting change, and if so, whether the change had been precleared. If the jurisdiction improperly failed to obtain preclearance, the court will order the jurisdiction to obtain preclearance before implementing the change. However, the court may not consider the merits of whether the change should be approved.[12][72]: 128–129 [138]: 556 [141]: 23  Jurisdictions may seek preclearance through either an "administrative preclearance" process or a "judicial preclearance" process. If a jurisdiction seeks administrative preclearance, the attorney general will consider whether the proposed change has a discriminatory purpose or effect. After the jurisdiction submits the proposed change, the attorney general has 60 days to interpose an objection to it. The 60-day period may be extended an additional 60 days if the jurisdiction later submits additional information. If the attorney general interposes an objection, then the change is not precleared and may not be implemented.[142]: 90–92  The attorney general's decision is not subject to judicial review,[143] but if the attorney general interposes an objection, the jurisdiction may independently seek judicial preclearance, and the court may disregard the attorney general's objection at its discretion.[27]: 559  If a jurisdiction seeks judicial preclearance, it must file a declaratory judgment action against the attorney general in the U.S. District Court for D.C. A three-judge panel will consider whether the voting change has a discriminatory purpose or effect, and the losing party may appeal directly to the Supreme Court.[144] Private parties may intervene in judicial preclearance lawsuits.[60]: 476–477 [142]: 90  In several cases, the Supreme Court has addressed the meaning of "discriminatory effect" and "discriminatory purpose" for Section 5 purposes. In Beer v. United States (1976),[145] the court held that for a voting change to have a prohibited discriminatory effect, it must result in "retrogression" (backsliding). Under this standard, a voting change that causes discrimination, but does not result in more discrimination than before the change was made, cannot be denied preclearance for having a discriminatory effect.[146]: 283–284  For example, replacing a poll tax with an equally expensive voter registration fee is not a "retrogressive" change because it causes equal discrimination, not more.[147]: 695  Relying on the Senate report for the Act, the court reasoned that the retrogression standard was the correct interpretation of the term "discriminatory effect" because Section 5's purpose is " 'to insure that [the gains thus far achieved in minority political participation] shall not be destroyed through new [discriminatory] procedures' ".[145]: 140–141  The retrogression standard applies irrespective of whether the voting change allegedly causes vote denial or vote dilution.[146]: 311  In 2003, the Supreme Court held in Georgia v. Ashcroft[60] that courts should not determine that a new redistricting plan has a retrogressive effect solely because the plan decreases the number of minority-majority districts. The court emphasized that judges should analyze various other factors under the "totality of the circumstances", such as whether the redistricting plan increases the number of "influence districts" in which a minority group is large enough to influence (but not decide) election outcomes. In 2006, Congress overturned this decision by amending Section 5 to explicitly state that "diminishing the ability [of a protected minority] to elect their preferred candidates of choice denies or abridges the right to vote within the meaning of" Section 5.[148] Uncertainty remains as to what this language precisely means and how courts may interpret it.[27]: 551–552, 916  Before 2000, the "discriminatory purpose" prong of Section 5 was understood to mean any discriminatory purpose, which is the same standard used to determine whether discrimination is unconstitutional. In Reno v. Bossier Parish (Bossier Parish II) (2000),[59] the Supreme Court extended the retrogression standard, holding that for a voting change to have a "discriminatory purpose" under Section 5, the change must have been implemented for a retrogressive purpose. Therefore, a voting change intended to discriminate against a protected minority was permissible under Section 5 so long as the change was not intended to increase existing discrimination.[146]: 277–278  This change significantly reduced the number of instances in which preclearance was denied based on discriminatory purpose. In 2006, Congress overturned Bossier Parish II by amending Section 5 to explicitly define "purpose" to mean "any discriminatory purpose."[61]: 199–200, 207 [149] Federal examiners and observersUntil the 2006 amendments to the Act,[58]: 50  Section 6 allowed the appointment of "federal examiners" to oversee certain jurisdictions' voter registration functions. Federal examiners could be assigned to a covered jurisdiction if the attorney general certified that The Department of Justice received 20 or more meritorious complaints that the covered jurisdiction denied its residents the right to vote based on race or language minority status; orThe assignment of federal examiners was otherwise necessary to enforce the voting rights guaranteed by the Fourteenth or Fifteenth Amendments.[132]: 235–236 Federal examiners had the authority to register voters, examine voter registration applications, and maintain voter rolls.[132]: 237  The goal of the federal examiner provision was to prevent jurisdictions from denying protected minorities the right to vote by engaging in discriminatory behavior in the voter registration process, such as refusing to register qualified applicants, purging qualified voters from the voter rolls, and limiting the hours during which persons could register. Federal examiners were used extensively in the years following the Act's enactment, but their importance waned over time; 1983 was the last year that a federal examiner registered a person to vote. In 2006, Congress repealed the provision.[132]: 238–239  Under the Act's original framework, in any jurisdiction certified for federal examiners, the attorney general could additionally require the appointment of "federal observers". By 2006, the federal examiner provision was used solely as a means to appoint federal observers.[132]: 239  When Congress repealed the federal examiner provision in 2006, Congress amended Section 8 to allow for the assignment of federal observers to jurisdictions that satisfied the same certification criteria that had been used to appoint federal examiners.[58]: 50  Federal observers are tasked with observing poll worker and voter conduct at polling places during an election and observing election officials tabulate the ballots.[132]: 248  The goal of the federal observer provision is to facilitate minority voter participation by deterring and documenting instances of discriminatory conduct in the election process, such as election officials denying qualified minority persons the right to cast a ballot, intimidation or harassment of voters on election day, or improper vote counting.[132]: 231–235  Discriminatory conduct that federal observers document may also serve as evidence in subsequent enforcement lawsuits.[132]: 233  Between 1965 and the Supreme Court's 2013 decision in Shelby County v. Holder to strike down the coverage formula, the attorney general certified 153 local governments across 11 states.[150] Because of time and resource constraints, federal observers are not assigned to every certified jurisdiction for every election.[132]: 230  Separate provisions allow for a certified jurisdiction to "bail out" of its certification.[150] BailoutUnder Section 4(a), a covered jurisdiction may seek exemption from coverage through a process called "bailout."[55] To achieve an exemption, a covered jurisdiction must obtain a declaratory judgment from a three-judge panel of the District Court for D.C. that the jurisdiction is eligible to bail out.[12][55] As originally enacted, a covered jurisdiction was eligible to bail out if it had not used a test or device with a discriminatory purpose or effect during the 5 years preceding its bailout request.[44]: 22, 33–34  Therefore, a jurisdiction that requested to bail out in 1967 would have needed to prove that it had not misused a test or device since at least 1962. Until 1970, this effectively required a covered jurisdiction to prove that it had not misused a test or device since before the Act was enacted five years earlier in 1965,[44]: 6  making it impossible for many covered jurisdictions to bail out.[44]: 27  However, Section 4(a) also prohibited covered jurisdictions from using tests or devices in any manner, discriminatory or otherwise; hence, under the original act, a covered jurisdiction would become eligible for bailout in 1970 by simply complying with this requirement. But in the course of amending the Act in 1970 and 1975 to extend the special provisions, Congress also extended the period of time that a covered jurisdiction must not have misused a test or device to 10 years and then to 17 years, respectively.[44]: 7, 9  These extensions continued the effect of requiring jurisdictions to prove that they had not misused a test or device since before the Act's enactment in 1965. In 1982, Congress amended Section 4(a) to make bailout easier to achieve in two ways. First, Congress provided that if a state is covered, local governments in that state may bail out even if the state is ineligible to bail out.[55] Second, Congress liberalized the eligibility criteria by replacing the 17-year requirement with a new standard, allowing a covered jurisdiction to bail out by proving that in the 10 years preceding its bailout request: The jurisdiction did not use a test or device with a discriminatory purpose or effect;No court determined that the jurisdiction denied or abridged the right to vote based on racial or language minority status;The jurisdiction complied with the preclearance requirement;The federal government did not assign federal examiners to the jurisdiction;The jurisdiction abolished discriminatory election practices; andThe jurisdiction took affirmative steps to eliminate voter intimidation and expand voting opportunities for protected minorities.Additionally, Congress required jurisdictions seeking bailout to produce evidence of minority registration and voting rates, including how these rates have changed over time and in comparison to the registration and voting rates of the majority. If the court determines that the covered jurisdiction is eligible for bailout, it will enter a declaratory judgment in the jurisdiction's favor. The court will retain jurisdiction for the following 10 years and may order the jurisdiction back into coverage if the jurisdiction subsequently engages in voting discrimination.[44][55][58]: 22–23 [151] The 1982 amendment to the bailout eligibility standard went into effect on August 5, 1984.[55] Between that date and 2013, 196 jurisdictions bailed out of coverage through 38 bailout actions; in each instance, the attorney general consented to the bailout request.[128]: 54  Between that date and 2009, all jurisdictions that bailed out were located in Virginia.[55] In 2009, a municipal utility jurisdiction in Texas bailed out after the Supreme Court's opinion in Northwest Austin Municipal Utility District No. 1 v. Holder (2009),[152] which held that local governments that do not register voters have the ability to bail out.[153] After this ruling, jurisdictions succeeded in at least 20 bailout actions before the Supreme Court held in Shelby County v. Holder (2013) that the coverage formula was unconstitutional.[128]: 54  Separate provisions allow a covered jurisdiction that has been certified to receive federal observers to bail out of its certification alone. Under Section 13, the attorney general may terminate the certification of a jurisdiction if 1) more than 50 percent of the jurisdiction's minority voting age population is registered to vote, and 2) there is no longer reasonable cause to believe that residents may experience voting discrimination. Alternatively, the District Court for D.C. may order the certification terminated.[132]: 237, 239 [150] Bilingual election requirementsTwo provisions require certain jurisdictions to provide election materials to voters in multiple languages: Section 4(f)(4) and Section 203(c). A jurisdiction covered by either provision must provide all materials related to an election—such as voter registration materials, ballots, notices, and instructions—in the language of any applicable language minority group residing in the jurisdiction.[57]: 209  Language minority groups protected by these provisions include Asian Americans, Hispanics, Native Americans, and Native Alaskans.[154] Congress enacted the provisions to break down language barriers and combat pervasive language discrimination against the protected groups.[57]: 200, 209  Section 4(f)(4) applies to any jurisdiction encompassed by the Section 4(b) coverage formula where more than five percent of the citizen voting age population are members of a single language minority group. Section 203(c) contains a formula that is separate from the Section 4(b) coverage formula, and therefore jurisdictions covered solely by 203(c) are not subject to the Act's other special provisions, such as preclearance. The Section 203(c) formula encompasses jurisdictions where the following conditions exist: A single language minority is present that has an English-illiteracy rate higher than the national average; andEither:The number of "limited-English proficient" members of the language minority group is at least 10,000 voting-age citizens or large enough to comprise at least five percent of the jurisdiction's voting-age citizen population; orThe jurisdiction is a political subdivision that contains an Indian reservation, and more than five percent of the jurisdiction's American Indian or Alaska Native voting-age citizens are members of a single language minority and are limited-English proficient.[57]: 223–224 Section 203(b) defines "limited-English proficient" as being "unable to speak or understand English adequately enough to participate in the electoral process".[57]: 223  Determinations as to which jurisdictions satisfy the Section 203(c) criteria occur once a decade following completion of the decennial census; at these times, new jurisdictions may come into coverage while others may have their coverage terminated. Additionally, under Section 203(d), a jurisdiction may "bail out" of Section 203(c) coverage by proving in federal court that no language minority group within the jurisdiction has an English illiteracy rate that is higher than the national illiteracy rate.[57]: 226  After the 2010 census, 150 jurisdictions across 25 states were covered under Section 203(c), including statewide coverage of California, Texas, and Florida.[155] Impactrefer to captionFinal page of the Voting Rights Act of 1965, signed by United States President Lyndon B. Johnson, President of the Senate Hubert Humphrey, and Speaker of the House John McCormackAfter its enactment in 1965, the law immediately decreased racial discrimination in voting. The suspension of literacy tests and the assignments of federal examiners and observers allowed for high numbers of racial minorities to register to vote.[96]: 702  Nearly 250,000 African Americans registered in 1965, one-third of whom were registered by federal examiners.[156] In covered jurisdictions, less than one-third (29.3 percent) of the African American population was registered in 1965; by 1967, this number increased to more than half (52.1 percent),[96]: 702  and a majority of African American residents became registered to vote in 9 of the 13 Southern states.[156] Similar increases were seen in the number of African Americans elected to office: between 1965 and 1985, African Americans elected as state legislators in the 11 former Confederate states increased from 3 to 176.[157]: 112  Nationwide, the number of African American elected officials increased from 1,469 in 1970 to 4,912 in 1980.[123]: 919  By 2011, the number was approximately 10,500.[158] Similarly, registration rates for language minority groups increased after Congress enacted the bilingual election requirements in 1975 and amended them in 1992. In 1973, the percent of Hispanics registered to vote was 34.9 percent; by 2006, that amount nearly doubled. The number of Asian Americans registered to vote in 1996 increased 58 percent by 2006.[57]: 233–235  After the Act's initial success in combating tactics designed to deny minorities access to the polls, the Act became predominately used as a tool to challenge racial vote dilution.[96]: 691  Starting in the 1970s, the attorney general commonly raised Section 5 objections to voting changes that decreased the effectiveness of racial minorities' votes, including discriminatory annexations, redistricting plans, and election methods such as at-large election systems, runoff election requirements, and prohibitions on bullet voting.[142]: 105–106  In total, 81 percent (2,541) of preclearance objections made between 1965 and 2006 were based on vote dilution.[142]: 102  Claims brought under Section 2 have also predominately concerned vote dilution.[96]: 708–709  Between the 1982 creation of the Section 2 results test and 2006, at least 331 Section 2 lawsuits resulted in published judicial opinions. In the 1980s, 60 percent of Section 2 lawsuits challenged at-large election systems; in the 1990s, 37.2 percent challenged at-large election systems and 38.5 percent challenged redistricting plans. Overall, plaintiffs succeeded in 37.2 percent of the 331 lawsuits, and they were more likely to succeed in lawsuits brought against covered jurisdictions.[159]: 654–656  By enfranchising racial minorities, the Act facilitated a political realignment of the Democratic and Republican parties. Between 1890 and 1965, Black disenfranchisement enabled the Democratic Party to dominate Southern politics. After Johnson signed the Act into law, newly enfranchised Black voters began to push the Democratic Party to the left throughout the South; this in turn pushed Southern white conservatives to switch their support from the Democratic to Republican party.[160]: 290  This trend caused the two parties to ideologically polarize, with the Democratic Party becoming more Liberal and the Republican Party becoming more Conservative.[160]: 290  The trends also created competition between the two parties,[160]: 290  which Republicans capitalized on by implementing the Southern strategy.[161] Over the subsequent decades, the creation of majority-minority districts to remedy racial vote dilution claims also contributed to these developments. By packing liberal-leaning racial minorities into small numbers of majority-minority districts, large numbers of surrounding districts became more solidly white, conservative, and Republican. While this increased the elected representation of racial minorities as intended, it also decreased white Democratic representation and increased the representation of Republicans overall.[160]: 292  By the mid-1990s, these trends culminated in a political realignment: the Democratic Party and the Republican Party became more ideologically polarized and defined as liberal and conservative parties, respectively; and both parties came to compete for electoral success in the South,[160]: 294  with the Republican Party controlling most of Southern politics.[24]: 203  Research shows that the Act successfully and massively increased voter turnout and voter registration, in particular among African Americans.[17][18] The act has also been linked to concrete outcomes, such as greater public goods provision (such as public education) for areas with higher black population shares and more members of Congress who vote for civil rights-related legislation.[20][21] A 2016 study in the American Journal of Political Science found "that members of Congress who represented jurisdictions subject to the preclearance requirement were substantially more supportive of civil rights-related legislation than legislators who did not represent covered jurisdictions."[20] A 2013 Quarterly Journal of Economics study found that the Act boosted voter turnout and increases in public goods transfers from state governments to localities with higher black population.[21] A 2018 study in The Journal of Politics found that Section 5 of the 1965 Voting Rights Act "increased black voter registration by 14–19 percentage points, white registration by 10–13 percentage points, and overall voter turnout by 10–19 percentage points. Additional results for Democratic vote share suggest that some of this overall increase in turnout may have come from reactionary whites."[17] A 2019 study in the American Economic Journal found that preclearance substantially increased turnout among minorities, even as far as to 2012 (the year prior to the Supreme Court ruling ending preclearance).[18] The study estimates that preclearance led to an increase in minority turnout of 17 percentage points.[18] A 2020 study found that the jurisdictions which had previously been covered by preclearance massively increased the rate of voter registration purges after the 2013 United States Supreme Court Shelby County v. Holder decision in which the "coverage formula" in Section 4(b) of the VRA that determined which jurisdictions had to presubmit changes in their election policies for federal approval was struck down.[15] Another 2020 study found that VRA coverage halved the incidence and the onset of political violence.[162] ConstitutionalityVoter eligibility provisionsEarly in the history of enforcement for the Act, the Supreme Court of the United States was rather quick to address both the constitutionality of the Act in its entirety as well as the constitutionality of several provisions relating to voter qualifications and prerequisites to voting. During the following year, in 1966, two legal cases were adjudicated by the Court regarding the Act. On the seventh day of March, in the landmark case of South Carolina v. Katzenbach (1966), the Supreme Court held that the Voting Rights Act of 1965 is a constitutional method to enforce the Fifteenth Amendment. A few months later, on the thirteenth day of June, the Supreme Court held that section 4(e) of the Voting Rights Act of 1965 was constitutional in the case of Katzenbach v. Morgan (1966). This section prohibits jurisdictions from administering literacy tests to citizens who attain a sixth-grade education in an American school in which the predominant language was Spanish, such as schools in Puerto Rico.[163] Although the Court had earlier held that literacy tests did not violate the Fourteenth Amendment, in the case of Lassiter v. Northampton County Board of Elections (1959), the Katzenbach-Morgan case allowed Congress could enforce Fourteenth Amendment rights—such as the right to vote—by prohibiting conduct that it deemed to interfere with such rights, even if that conduct may not be independently unconstitutional.[164]: 405–406 [165]: 652–656  After Congress created a nationwide ban on all literacy tests and similar devices in 1970, in the case of Oregon v. Mitchell (1970), the Supreme Court upheld the ban as being constitutional.[124][166] In that case, the Court also addressed the constitutionality of various other provisions relating to voter qualifications and prerequisites to voting; the Court upheld Section 202 of the 1965 law, which prohibits every state and local government from requiring people to live in their borders for longer than 30 days before allowing them to vote in a presidential election. Additionally, the Court upheld the provision lowering the minimum voting age to 18 years in federal elections, but it held that Congress exceeded its power by lowering the voting age to 18 in state elections; this precipitated the ratification of the Twenty-sixth Amendment the following year, which lowered the voting age in all elections from 21 years to 18 years in age. The Court was deeply divided in the Oregon-Mitchell case and a majority of the justices did not agree on one rationale for the holding.[124]: 353 [166]: 118–121  Section 2 results testThe question of constitutionality regarding section 2 of the Voting Rights Act of 1965, which contains a general prohibition on discriminatory voting laws, has not been definitively explained by the Supreme Court. As amended in 1982, section 2 prohibits any voting practice that has a discriminatory effect, irrespective of whether the practice was enacted or is administered for the purpose of discriminating. This "results test" contrasts with the Fourteenth and Fifteenth Amendments, both of which directly prohibit only purposeful discrimination. Given this disparity, whether the Supreme Court would uphold the constitutionality of section 2 as appropriate legislation that was passed to enforce the Fourteenth and Fifteenth Amendments, and under what rationale, remains unclear.[27]: 758–759  In Mississippi Republican Executive Opinion v. Brooks (1984),[167] the Supreme Court summarily affirmed, without a written opinion, a lower court's decision that 1982 amendment to section 2 is constitutional.[168] Justice Rehnquist, joined by Chief Justice Burger, dissented from the opinion. They reasoned that the case presented complex constitutional issues that warranted a full hearing. When making later decisions, the Supreme Court is more likely to disregard a previous judgment if it lacks a written opinion, but for lower courts the Supreme Court's unwritten summary affirmances are as binding as are Supreme Court judgments with written opinions. Partially due to Brooks, the constitutionality of the section 2 results test has since been unanimously upheld by lower courts.[27]: 759–760  The case of Brnovich v. Democratic National Committee (2021) evaluated the applicability of section 2 of the 1965 law in the wake of the decision in the case of Shelby County v. Holder (2013). The Democratic National Committee asserted a set of Arizona election laws and policies were discriminatory towards Hispanics and Native Americans under section 2 of the Voting Rights Act of 1965. While lower courts upheld the election laws, an en banc Ninth Circuit reversed the decision and found these laws to be in violation of section 2 of the 1965 law.[169] The Arizona law was upheld by the Supreme Court after it introduced the means to review section 2 challenges.[88][89][91] Coverage formula and preclearanceThe Supreme Court has upheld the constitutionality of the Section 5 preclearance requirement in three cases. The first case was South Carolina v. Katzenbach (1966),[170] which was decided about five months after the Act's enactment. The court held that Section 5 constituted a valid use of Congress's power to enforce the Fifteenth Amendment, reasoning that "exceptional circumstances" of pervasive racial discrimination, combined with the inadequacy of case-by-case litigation in ending that discrimination, justified the preclearance requirement.[170]: 334–335 [171]: 76  The court also upheld the constitutionality of the 1965 coverage formula, saying that it was "rational in both practice and theory" and that the bailout provision provided adequate relief for jurisdictions that may not deserve coverage.[170]: 330 [171]: 76–77  The Supreme Court again upheld the preclearance requirement in City of Rome v. United States (1980).[172] The court held that because Congress had explicit constitutional power to enforce the Reconstruction Amendments "by appropriate legislation", the Act did not violate principles of federalism. The court also explicitly upheld the "discriminatory effect" prong of Section 5, stating that even though the Fifteenth Amendment directly prohibited only intentional discrimination, Congress could constitutionally prohibit unintentional discrimination to mitigate the risk that jurisdictions may engage in intentional discrimination. Finally, the court upheld the 1975 extension of Section 5 because of the record of discrimination that continued to persist in the covered jurisdictions. The court further suggested that the temporary nature of the special provisions was relevant to Section 5's constitutionality.[171]: 77–78  The final case in which the Supreme Court upheld Section 5 was Lopez v. Monterey County (Lopez II) (1999).[173] In Lopez II, the court reiterated its reasoning in Katzenbach and Rome, and it upheld as constitutional the requirement that covered local governments obtain preclearance before implementing voting changes that their parent state required them to implement, even if the parent state was not itself a covered jurisdiction.[171]: 78 [174]: 447  The 2006 extension of Section 5 was challenged before the Supreme Court in Northwest Austin Municipal Utility District No. 1 v. Holder (2009).[152] The lawsuit was brought by a municipal water district in Texas that elected members to a water board. The District wished to move a voting location from a private home to a public school, but that change was subject to preclearance because Texas was a covered jurisdiction. The District did not register voters, and thus it did not appear to qualify as a "political subdivision" eligible to bail out of coverage. Although the court indicated in dicta (a non-binding part of the court's opinion) that Section 5 presented difficult constitutional questions, it did not declare Section 5 unconstitutional; instead, it interpreted the law to allow any covered local government, including one that does not register voters, to obtain an exemption from preclearance if it meets the bailout requirements.[175][176] In a 5–4 decision in Shelby County v. Holder (2013),[177] the Supreme Court struck down Section 4(b) as unconstitutional.[13][136] The court reasoned that the coverage formula violates the constitutional principles of "equal sovereignty of the states" and federalism because its disparate treatment of the states is "based on 40 year-old facts having no logical relationship to the present day", rendering the formula outdated.[13][135] The court did not strike down Section 5, but without Section 4(b), no jurisdiction may be subject to Section 5 preclearance unless Congress enacts a new coverage formula.[14] After the decision, several states that were fully or partially covered—including Texas, Mississippi, North Carolina, and South Carolina—implemented laws that were previously denied preclearance. This prompted new legal challenges to these laws under other provisions unaffected by the court's decision, such as Section 2.[178]: 189–200  Research has shown that the coverage formula and the requirement of preclearance substantially increased turnout among racial minorities, even as far as the year before Shelby County.[18] Some jurisdictions that had previously been covered by the coverage formula increased the rate of voter registration purges after Shelby County.[179] On 1 July 2021, the Act's preclearance requirements were further weakened at the state and local level following the Brnovich v. Democratic National Committee in a 6-3 Supreme Court ruling which held that Section 2 preclearance provisions could not apply to out-of-precinct voting or ballot collecting.[16][11] Racial gerrymanderingMain article: Gerrymandering in the United States: Affirmative racial gerrymanderingWhile Section 2 and Section 5 prohibit jurisdictions from drawing electoral districts that dilute the votes of protected minorities, the Supreme Court has held that in some instances, the Equal Protection Clause of the Fourteenth Amendment prevents jurisdictions from drawing district lines to favor protected minorities. The court first recognized the justiciability of affirmative "racial gerrymandering" claims in Shaw v. Reno (1993).[180] In Miller v. Johnson (1995),[181] the court explained that a redistricting plan is constitutionally suspect if the jurisdiction used race as the "predominant factor" in determining how to draw district lines. For race to "predominate", the jurisdiction must prioritize racial considerations over traditional redistricting principles, which include "compactness, contiguity, [and] respect for political subdivisions or communities defined by actual shared interests."[181]: 916 [182]: 621  If a court concludes that racial considerations predominated, then the redistricting plan is considered "racially gerrymandered" and must be subjected to strict scrutiny, meaning that the redistricting plan will be upheld as constitutional only if it is narrowly tailored to advance a compelling state interest. In Bush v. Vera (1996),[183]: 983  a plurality of the Supreme Court assumed that complying with Section 2 or Section 5 constituted compelling interests, and lower courts have allowed only these two interests to justify racial gerrymandering.[27]: 877  See alsoflagUnited States portaliconLaw portaliconPolitics portalFederal lawsNational Voter Registration Act of 1993 (NVRA)Help America Vote Act (HAVA)Uniformed and Overseas Citizens Absentee Voting Act (UOCAVA)Attempted federal legislationFor the People Act (2019 and 2021)John Lewis Voting Rights Act (2019 and 2021)State lawsCalifornia Voting Rights ActVoting Rights Act of VirginiaMore

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