Be Bold: Comparative and International Arguments for a Campaign to Re-Enfranchise the United States’ Prison Population

Hannah Tuttle


Today, an estimated 5.17 million Americans are disfranchised based on a felony conviction.1 In the last four years, over one million former felons have been re-enfranchised as states have lessened their voting restrictions, bringing the total down from the 2016 high of 6.11 million people disenfranchised following a felony conviction .2 The massive number of individuals in the criminal justice system, coupled with extremely punitive voting restrictions for felons, results in the disenfranchisement of one out of every forty-four adults in the U.S. and one out of every sixteen Black citizens.3 In the seven states with the most onerous disenfranchisement rules–Alabama, Florida, Kentucky, Mississippi, Tennessee, Virginia, and Wyoming–one person out of every seven Black people is disenfranchised.4

Felon disenfranchisement, or “the act of taking away the right to vote in public elections from” those convicted of a felony,5 is widespread practice in the United States. Many states disenfranchise former felons long after they have left prison.6 Disenfranchisement initially served as a specific and tailored form of punishment for a certain class of crime involving moral offenses or election fraud.7 Only two states, Maine and Vermont, currently extend the right to vote to their incarcerated populations.8 In the rest of the country, disenfranchisement of both current and former prison inmates has been both broadened and weaponized to silence the political voice of voters of color in the United States.9

The United States shares the common law root of felon disenfranchisement with many other Western democracies. No other country from that list, however, denies the vote to such large swaths of their population. The history of American felon disenfranchisement policies reveals increasingly blatant racial animus. These policies began as race-neutral and ancient deterrence methods and became tools used to derogate the rights of Americans of color. Other countries with similarly fraught racial histories have recognized the racial implications of their felony disenfranchisement laws and sought to correct them–the U.S. should do the same.

This essay begins with an overview of racially-motivated felony disenfranchisement in the U.S. and outlines the recent battle over enfranchisement in Florida. It then compares U.S. practice with recent enfranchisement cases in the constitutional courts of Australia and South Africa, and considers the pressure exerted to end the practice by public international law bodies. It concludes that prisoner enfranchisement is logistically, politically, and demonstrably possible in the U.S., looking to longstanding practices in Maine and Vermont.

The History of Racially-Motivated Felon Disenfranchisement in the U.S.

Blanket restrictions on voting rights did not exist before the Reconstruction Era. Instead, the early colonial governments disfranchised eligible voters for limited “moral” violations, either temporarily or permanently.10 This idea was imported from Europe and based on the British idea of a “civil death,” or the loss of legal rights attendant to criminal status, including voting.11 The permanent loss of voting rights were “limited to very serious crimes, and were implemented only upon judicial pronouncement in individual cases.”12

Several important facets of pre-founding colonial disenfranchisement must be emphasized: first, disenfranchisement represented a sort of public shaming articulated by law; second, it required courts to implement (it was not generally automatic); and third, it was limited to a discrete set of crimes involving moral turpitude or voting specifically.13 The practice was based on the idea that a person who committed a crime that was either sufficiently serious or election-related would face public shaming when required to disclose to the community that he was unable to vote. The embarrassment the disenfranchised person was expected to feel as a result of their loss of voting rights is difficult to square with the modern day, where even in the highest turnout election in modern American history, only 66 percent of eligible voters chose to cast a ballot.14

On February 3, 1870, after the Civil War and during the Reconstruction era, Black American men were first granted the right to vote through the Fifteenth Amendment.15 Unlike the earlier Reconstruction Act of 1867, the Amendment represented a negative right–Black Americans were no longer denied the right to vote on the basis of race.16 Despite lacking clear enforcement mechanisms, it had profound effects: two-thirds of all eligible Black voters cast ballots and contributed to electing fifteen percent of all Southern officeholders.17

Unfortunately, it did not last. Felon disenfranchisement was weaponized in the post-Reconstruction era to limit the power of Black Americans. Newly freed from the military rule imposed by the North, white Southerners rushed to reform their constitutions and voting laws in order to impose stringent barriers on Black citizens eager to exercise their right to vote. Techniques included devices such as poll taxes, grandfather clauses, literacy tests, and whites-only primaries.18

Importantly, this era also included the use of blanket criminal disenfranchisement. Specifically, some states chose to adjust the crimes that led to disenfranchisement. Mississippi changed disenfranchisement from applying after the conviction of any crime to only after the conviction of crimes more frequently committed by Black citizens.19 In Alabama, misdemeanors were effectively included in its “moral turpitude” descriptor, allowing the state to both broaden disenfranchisement’s reach and focus it on Black citizens.20 In South Carolina, crimes such as breaking into a house, sodomy, and miscegenation resulted in disenfranchisement, but thefts and murders did not.21

These techniques were both successful and validated by the courts. One historian found that by 1903, Alabama’s new felon disenfranchisement laws had eliminated the voting rights of ten Black citizens to every one white.22 The Lodge Bill, designed to allow enforcement of the Fifteenth Amendment to protect Black voting rights, died at the filibuster stage.23 Advocates of Black political rights then turned to the courts, where the Supreme Court rendered the Fifteenth Amendment toothless in Giles v. Harris by declining to add Black Americans who were prevented from voting by discriminatory laws back to the voter rolls.24 Instead, the Court found that the proper relief could only come from the political branches of the federal government.25

As the prison population exploded in the past forty years,26 the tide of public opinion has swung remarkably towards felon re-enfranchisement. Between 2016 and 2020 alone, many states successfully expanded felon voting rights for non-incarcerated offenders.27 One particular state illustrates this trend and the battles to come: Florida.

Florida and the Battle for Enfranchisement

In fall 2018, Florida voters easily surpassed the 60 percent threshold28 needed to amend the Florida Constitution to give former felons, roughly 1.5 million, the right to vote.29 This replaced the “clemency boards,” a facet of gubernatorial power historically common in constitutions across the South, which required individualized governor approval before a returning citizen could be afforded the vote.30 Known as Amendment 4, the 2018 referendum set off a series of battles implicating two branches of state government, the public, and the federal court system. In a state like Florida, where more than one out of every seven Black adults is disqualified from voting because of a felony conviction31 and national contests often rest on a knife’s edge, re-enfranchised individuals could be determinative in future elections.

The movement to get Amendment 4 on the ballot and passed required immense grassroots mobilization.32 Due in part to the massive attention garnered by the state after the 537-vote margin that decided the 2000 presidential election, progressives in the state began a campaign to re-enfranchise felons.33 The Florida Rights Restoration Coalition, a grassroots membership organization run by “returning citizens” (their preferred term for formerly incarcerated persons) dedicated to the re-enfranchisement of felons in Florida, spearheaded this effort.34 The 2018 amendment passed with nearly 65 percent of Florida voters in favor.35

After the amendment became law, the Republican-dominated state legislature limited its effects by passing Senate Bill 7066, requiring that newly enfranchised felons pay all their outstanding court fines and fees, including restitution, before regaining their right to vote.36 In response, proponents of Amendment 4 took the fight to court and claimed that the measure was an impermissible poll tax, a vestige of the Reconstruction era. Although the petitioners won in federal district court, a three-judge panel of the Eleventh Circuit first stayed the trial court’s ruling and then reheard the case en banc.37 The rehearing led to a victory for the Republican state government.38

Florida is an illustration of contemporary battles over returning citizen voting rights, one that is mirrored in other states with split party control of state government branches in the U.S.’s federalist system.39 Notably, with the exception of the Florida state legislature action, no states appear to have adopted more restrictive felon voting laws in the recent decades.40 The push towards re-enfranchisement in the U.S. is largely unidirectional in the twenty-first century.

Comparative International Law and Australia

Other major Western democracies, several of whom have prisoner voting laws based on an identical common law root, have not widely disenfranchised their formerly incarcerated populations. These countries have made prisoner enfranchisement their default, with derogations of the right to vote allowable only in specific and limited circumstances–the opposite of the position taken by states in the U.S. where disenfranchisement is the norm and re-enfranchisement the exception. According to an ACLU study, all foreign constitutional courts that have faced a disenfranchisement law have determined that the automatic, blanket disqualification of prisoners from voting violates basic democratic principles.41 This section specifically describes felon disenfranchisement in Australia, although the UK, South Africa, and Canada could also feature here.42

In Australia, constitutional law has been termed a “Washminster” system, pulling from both American and British legal practice.43 Notably, Australia has a federalist system modeled on the U.S., meaning that prisoners have different rights in different jurisdictions. Also similar to the U.S., the Australian criminal law system has been plagued by accusations of racial discrimination. Felon disenfranchisement statutes, racially neutral on their face, have a disparate racial impact: 48 percent of Aboriginal prisoners are disenfranchised, but only 39 percent of non-Aboriginal prisoners are.44 Despite representing only two percent of the Australian population as a whole, 28 percent of the total prison population is Aboriginal.45 This racial disparity mirrors the situation in the United States. One commentator put the Aboriginal Australians’ plight into terms easily applicable to communities of color in the U.S.: “Aboriginal people have been disproportionately excised from the voting populace by being imprisoned at a much higher rate, yet voting is the strongest means available in a democracy to secure their own self-determination.”46

From the beginning of the twentieth century until 1983, persons sentenced for an offense punishable by imprisonment for over one year could not vote in Australia47–an astonishingly similar criterion to current felon disenfranchisement in the United States. This set off several decades of partisan back-and-forth, where the ability of prisoners to vote depended in part on the political party in power.48 In 2007, the High Court of Australia heard a challenge to prisoner voting restrictions in Roach v. Electoral Commissioner.49 In a 4-2 majority, the Court held that disenfranchisement of a group of adult citizens without a substantial reason is inconsistent with a system of representative government. Although it struck down a law allowing disenfranchisement for any crime, it allowed a provision allowing disenfranchisement for prisoners serving three or more years.50 The provision remained through the 2018 election, though specific voting qualifications remain under the states’ and territories’ discretion.51 In the end, the Roach decision could be understood as the Court seeking to balance total prisoner enfranchisement and governmental power by requiring Parliament to be specific about what crimes it deemed serious enough to disenfranchise,52 a higher bar than Congress and the courts have required of U.S. states.

Public International Law: The U.S. as an Outlier

Public international human rights doctrine supports extending the right to vote for prisoners, subject to certain and specific derogations, particularly where disenfranchisement has proven to have a racially discriminatory effect.53 Human rights instruments come from a variety of international law epochs and include the International Covenant on Civil and Political Rights (ICCPR) (1966/1992), the International Covenant on the Elimination of All Forms of Racial Discrimination (CERD) (1965/1994), the Universal Declaration of Human Rights (1948), the Venice Commission Code of Good Practice in Electoral Matters (2002), the European Convention on Human Rights (1950), the Standard Minimum Rules for the Treatment of Prisoners (1990), and the Basic Principles for the Treatment of Prisoners (1990).54 Major state courts, including the Australian High Court, the Canadian Supreme Court, and the South African Constitutional Court have all cited public international law documents in their opinions supporting prisoner enfranchisement.55

The ICCPR, one of the major international human rights instruments to which the United States is a party, does not support blanket voting prohibitions for prisoners. The body tasked with interpreting the document has said that it “fails to discern the justification for such a practice in modern times, considering that it amounts to an additional punishment and that it does not contribute towards the prisoner’s reformation and social rehabilitation.”56 The Australian High Court and the European Court of Human Rights both cited the ICCPR in their respective prisoner voting cases.57

Another particularly compelling international human rights instrument pertaining to U.S. disenfranchisement law is CERD, to which the United States is a signatory.58 The body charged with interpreting CERD, the U.N. Committee on the Elimination of Racial Discrimination, has “highlighted and criticized U.S. felony disenfranchisement in its responses to every progress report submitted by the United States.”59 Recently, the Committee reaffirmed its determination to monitor U.S. abuses, even though former President Trump refused to nominate a representative to the body and the country’s mandatory submission for periodic review was a year and a half overdue.60 Major public international law bodies are in agreement–derogation of the right to vote is a severe punishment in a representative democracy and should not be the norm when someone is convicted of a felony, particularly when racial disparities are evident.


Felony disenfranchisement in the United States has been fraught with racial animus since the late nineteenth century, when it completed its transition from a very limited “civil death” for specific offenders61 to blanket restrictions overwhelmingly targeting potential voters of color. It has been condemned both by foreign constitutional courts in similarly racially-fraught countries and by the bodies tasked with interpreting human rights treaties to which the U.S. is a signatory. It is long past time that the U.S. moves beyond the outdated and destructive practice that is felony disenfranchisement.

But that isn’t far enough. Removing restrictions on felons who are finished serving their sentence is an important start but changing the status quo to prisoner enfranchisement is crucial. Allowing prisoners to vote would bring the U.S. in line with other liberal democracies and be more consistent with U.S. international obligations, to say nothing of honoring the centrality of voting to representative democracies. Most Western democracies recognize the fundamental importance of extending voting rights to those who are incarcerated–especially in countries with discriminatory criminal laws and racist histories, like Australia. Progress, though slow and piecemeal, can be made: in the run up to the 2020 election, Democratic candidates were asked at a town hall whether prisoners should be allowed to vote,62 a question that might have seemed outside the realm of possibility only a few decades ago.

Two U.S. states have demonstrated from their inception that prisoner enfranchisement is possible. Maine and Vermont prove that extending the vote to incarcerated individuals does not undermine the laws of the state, despite opponents’ arguments. Proponents from both sides of the political aisle argue that allowing prisoners to vote reduces recidivism, combats loneliness, and prepares incarcerated individuals for reengagement with civic life, thereby promoting rehabilitation–one of the alleged purposes of incarceration.63 These states demonstrate alternative ways of conceptualizing incarceration within in the U.S.: one standing for the proposition that citizenship does not end at the prison gate.

Those familiar with the northeastern U.S. might note that both Maine and Vermont are overwhelmingly white states.64 As a result, they appear to have largely sidestepped the racial animus that fueled the Southern states’ attempt to disenfranchise voters of color, perhaps in part because so few voters of color live there.65 However, recent events demonstrate that there is substantial movement among even more populous and diverse states. In 2019, at least eight states (Connecticut, Hawaii, Massachusetts, Nebraska, New Jersey, New Mexico, New York, and Virginia) and the District of Columbia took legislative steps to re-enfranchise prisoners.66 Representative Ayanna Pressley has also introduced federal legislation to enable incarcerated people to vote.67 Although many of these initiatives face an uphill battle to passage due to the fractured nature of state government branch support and hostility among Republicans in Congress, they evince greater awareness and enthusiasm for the proposition of prisoner re-enfranchisement nationwide.68

After the 2020 summer of racial justice protests and the promise of a new and groundbreakingly diverse administration,69 we should not fear bold moves. Felon disenfranchisement no longer resembles its initial iteration and the modern version has the effect of disproportionately silencing voters of color. The U.S. is experiencing a reawakening regarding its complicated racial past and current forms of systemic racism. Felon disenfranchisement is on the wane as states across the country rethink their blanket disenfranchisement laws–even a conservative state like Florida was able to garner the support of over 60 percent of voters to amend the state constitution and re-enfranchise 1.5 million returning citizens in 2018.70

South Africa, a country with a deeply racist past not unlike that of the United States, represents a poignant closing note. The South African constitutional court recently re-enfranchised 146,000 incarcerated individuals by striking down a provision denying the right to vote to prisoners. The Court wrote that “[i]n light of our history where the denial of the vote was used to entrench white supremacy and to marginalize the great majority of the people of our country, it is for us a precious right which must be vigilantly respected and protected.”71

  1. ↑ 1 Christopher Uggen et al., Locked Out 2020: Estimates of People Denied Voting Rights Due to a Felony Conviction, The Sent’g Project (Oct. 30, 2020), [].
  2. ↑ 2
    Christopher Uggen et al., 6 Million Lost Voters: State-Level Estimates of Felony Disenfranchisement, 2016, The Sent’g Project (Oct. 6, 2016), [].
  3. ↑ 3
    Uggen et al., supra note 1.
  4. ↑ 4
  5. ↑ 5
    Disenfranchisement, Black’s Law Dictionary (11th ed. 2019).
  6. ↑ 6
    Uggen et al., supra note 1.
  7. ↑ 7
    Alec C. Ewald, “Civil Death”: The Ideological Paradox of Criminal Disenfranchisement Law in the United States, 2002 Wis. L. Rev. 1045, 1061 (2002).
  8. ↑ 8
    See discussion infra Conclusion.
  9. ↑ 9
    See Uggen et al., supra note 1.
  10. ↑ 10
    Ewald, supra note 7, at 1060–61 (noting that while Plymouth permanently deprived people deemed “grosly scandalouse as lyers [sic] drunkards [and] [s]wearers” of their right to vote, Maryland and Connecticut allowed the courts to restore voting rights to felons) (citation omitted).
  11. ↑ 11
    Id. at 1059.
  12. ↑ 12
    Id. at 1060.
  13. ↑ 13
    Id. at 1061.
  14. ↑ 14
    Kevin Schaul, Kate Rabinowitz & Ted Mellnik, 2020 Turnout is the Highest in over a Century, Wash. Post (Nov. 23, 3030), [].
  15. ↑ 15
    U.S. Const. amend. XV; see also Guy-Uriel E. Charles & Luis E. Fuentes-Rohwer, Slouching Toward Universality: A Brief History of Race, Voting, and Political Participation, 62 How. L.J. 809, 823–24 (2019).
  16. ↑ 16
    Charles & Fuentes-Rohwer, supra note 15, at 825.
  17. ↑ 17
  18. ↑ 18
    Ewald, supra note 7, at 1087.
  19. ↑ 19
    Id. at 1088.
  20. ↑ 20
    Id. at 1091.
  21. ↑ 21
    Id. at 1089.
  22. ↑ 22
    Id. at 1091.
  23. ↑ 23
  24. ↑ 24
    Giles v. Harris, 189 U.S. 475, 486 (1903); Charles & Fuentes-Rohwer, supra note 15, at 833–34.
  25. ↑ 25
    Giles, 189 U.S. at 489.
  26. ↑ 26
    The Sentencing Project estimates that the prison population has grown by 500 percent in the past forty years. Criminal Justice Facts, The Sent’g Project: The Facts, (last visited Dec. 20, 2020) []; see generally Michelle Alexander, The New Jim Crow: Mass Incarceration in the Age of Colorblindness (2010).
  27. ↑ 27
    Uggen et al., supra note 1.
  28. ↑ 28
    According to Ballotpedia, nearly 65 percent of Florida voters voted in favor of the amendment. Florida Amendment 4, Voting Rights Restoration for Felons Initiative (2018), Ballotpedia (2018),,_Voting_Rights_Restoration_for_Felons_Initiative_(2018) (last visited Nov. 9, 2020) [] [hereinafter Florida Amendment 4].
  29. ↑ 29
    Steve Bousquet, A Long, Hot Summer of Building Support to Grant Felons the Right to Vote, Tampa Bay Times (July 19, 2018), [].
  30. ↑ 30
    Last Week Tonight, Felony Disenfranchisement: Last Week Tonight with John Oliver, YouTube (Sept. 9, 2018) [].
  31. ↑ 31
    Uggen et al., supra note 1.
  32. ↑ 32
    See Laws Governing the Initiative Process in Florida, Ballotpedia, [] (last visited Nov. 23, 2020) (describing in detail the hurdles of getting an amendment on a ballot, which includes the requirement that organizers collect signatures equally 8 percent of the total number of votes cast in the last presidential election [in 2018, this amounted to 766,200 signatures] spread across at least fourteen of the state’s twenty-seven congressional districts).
  33. ↑ 33
    George Brooks, Comment, Felon Disenfranchisement: Law, History, Policy, and Politics, 32 Fordham Urb. L.J. 851, 851 (2005).
  34. ↑ 34
    Our Mission Statement, Fla. Rts. Restoration Coalition, [] (last visited Nov. 23, 2020).
  35. ↑ 35
    Florida Amendment 4, supra note 28.
  36. ↑ 36
    Patricia Mazzei, Floridians Gave Ex-Felons the Right to Vote. Lawmakers Just Put a Big Obstacle in Their Way, N.Y. Times (May 3, 2019), []. The new repayment requirements passed along party lines late in a legislative session, appended to a previously unrelated bill that left even some Republican lawmakers unhappy. Id. See also Florida Senate Bill 7066 (2019), Ballotpedia, [] (last visited Apr. 2, 2020) [hereinafter SB 7066].
  37. ↑ 37
    Alex Pickett, Full 11th Circuit Rules Against Florida Felons in Voting Rights Case, Courthouse News Serv. (Sept. 11, 2020), []; SB 7066, supra note 36.
  38. ↑ 38
    Jones v. Governor of Fla., 975 F.3d 1016 (2020).
  39. ↑ 39
    See, e.g., Vann R. Newkirk II, California Extends the Ballot to Jails, The Atlantic (Oct. 4, 2016), []; Felon Disenfranchisement–Scope of Governor’s Clemency Power–Supreme Court of Virginia Holds That Executive Order Restoring Voting Rights En Masse is Unconstitutional–Howell v. McAuliffe, 788 S.E.2d 706 (Va. 2016), 130 Harv. L. Rev. 1970, 1970 (2017); and Michael Wines, Kentucky Gives Voting Rights to Some 140,000 Former Felons, N.Y. Times (Dec. 12, 2019), [].
  40. ↑ 40
    See generally Uggen et al., supra note 1.
  41. ↑ 41
    Out of Step with the World: An Analysis of Felony Disenfranchisement in the U.S. and Other Democracies, (ACLU, New York, N.Y.), May 2006, at 4.
  42. ↑ 42
    See generally Kevin Lineberger, Felon Voting: The Call for an Australian Compromise, 41 Mitchell Hamline L. J. Pub. Pol’y & Practice 22 (2020).
  43. ↑ 43
    Megan A. Winder, Comment, Disproportionate Disenfranchisement of Aboriginal Prisoners: A Conflict of Law that Australia Should Address, 19 Pac. Rim L. & Pol’y J. 387, 391–92 (2010).
  44. ↑ 44
    Id. at 409.
  45. ↑ 45
    Mary Y. Carroll, Locked In and Locked Out: Applying Charming Betsy to U.S. Felony Disenfranchisement, 38 Yale L. & Pol’y Rev. 397, 408 (2013).
  46. ↑ 46
    Winder, supra note 43, at 395.
  47. ↑ 47
    Id. at 393.
  48. ↑ 48
    See Lineberger, supra note 42, at 31.
  49. ↑ 49
    Roach v Electoral Comm’r (2007) 233 CLR 162 (Austl.).
  50. ↑ 50
    Winder, supra note 43, at 388.
  51. ↑ 51
    Lineberger, supra note 42, at 32.
  52. ↑ 52
    Id. at 33.
  53. ↑ 53
    Carroll, supra note 45, at 405.
  54. ↑ 54
    ACLU, supra note 41, at 24–25.
  55. ↑ 55
    Carroll, supra note 45, at 408–09.
  56. ↑ 56
    Winder, supra note 43, at 413; U.N. Int’l Covenant on Civ. & Political Rts., Hum. Rts. Comm., Consideration of Reports Submitted by States Parties Under Article 10 of the Covenant, para. 10, U.N. Doc. CCPR/CO/73/UK (Dec. 6, 2001).
  57. ↑ 57
    Lineberger, supra note 42, at 25.
  58. ↑ 58
    ACLU, supra note 41, at 24.
  59. ↑ 59
    Carroll, supra note 45, at 413.
  60. ↑ 60
    US Does Not Nominate Representative to Critical Rights Body, Hum. Rts. Watch (Apr. 16, 2019), [].
  61. ↑ 61
    Ewald, supra note 7, at 1063–64.
  62. ↑ 62
    Mazzei, supra note 36.
  63. ↑ 63
    Neely Baugh-Dash, Note, Criminal Disenfranchisement: Deconstructing Its Justification and Crafting State-Centered Solutions, 7 Belmont L. Rev. 123, 138 (2019).
  64. ↑ 64
    According to Census Bureau data, Maine is 94.4% white, 1.7% Black, and 1.8% Hispanic or Latino. QuickFacts: Maine, Census Bureau, [] (last visited Dec. 20, 2020). Vermont is 94.2% white, 1.4% Black, and 2.0% Hispanic or Latino. QuickFacts: Vermont, Census Bureau, [] (last visited Dec. 20, 2020).
  65. ↑ 65
    Nicole Lewis, In Just Two States, All Prisoners Can Vote. Here’s Why Few Do., The Marshall Project (June 11, 2019), [].
  66. ↑ 66
    Daniel Nichanian, When People in Prison Can Vote, Officials “Treat Them With Some Respect,” The Appeal (Nov. 22, 2019), [].
  67. ↑ 67
  68. ↑ 68
    See generally Uggen et al., supra note 1.
  69. ↑ 69
    Janet Hook, Biden’s Cabinet: Expertise, Diversity and an Obama Class Reunion, L.A. Times (Dec. 19, 2020), [].
  70. ↑ 70
    According to Ballotpedia, nearly 65 percent of Florida voters voted in favor of the amendment. Florida Amendment 4, supra note 28.
  71. ↑ 71
    Carroll, supra note 45, at 410.

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