Jeffrey Toobin writes that "after the 2010 midterm elections, nineteen states passed laws that put up barriers to voting, including new photo-I.D. and proof-of-citizenship requirements, and restrictions on early and absentee voting. In most of those states, Republicans controlled the governorship and the legislature. The purported justification for the changes was to limit in-person voter fraud, but that claim was fraudulent itself, since voter fraud is essentially nonexistent." "It is against this backdrop that, next month, the Supreme Court will take up a challenge to the Voting Rights Act of 1965, the most effective law of its kind in the history of the United States.