Beyond Access: The Future of Voting Rights in the United States

by Christian Hosam

“The Act gives a broad interpretation to the right to vote, recognizing that voting includes ‘all action necessary to make a vote effective.’” 

– Earl Warren¹

Supreme Court Chief Justice Earl Warren wrote this in the 1969 decision Allen v. State Board of Elections. But what exactly does it mean for a vote to be “effective” and how has this changed over time? The Allen decision held that Section 5 of the Voting Rights Act of 1965 (VRA) was designed to help address both the subtle and obvious ways that state regulations took away the vote on the basis of race.² This decision extended the logic of the VRA beyond discrimination at the ballot box to the affirmative right of minority voters to have political representation. Today, this remains the terrain upon which many of the thorniest legal battles around voting rights are fought.

Particularly since the 2013 Shelby County v. Holder decision, which substantially weakened Section 5 of the VRA, there have been legal challenges to determine the constitutional limits of racial protection that remain without preclearance requirements to serve as guardrails for both sides.³ While the Supreme Court has adjudicated many cases, especially within the context of Section 2 claims (the part of the legislation that is focused on the dilution of minority votes), there is no intuitive definition, either before or after Shelby, for a threshold that clearly defines sufficient minority political participation, nor should there be. The Voting Rights Act was not designed—and therefore not equipped—to take up the challenge of determining the best way to ensure that communities of color around the country are able to best and most effectively exercise their constitutional right to vote.

There is no intuitive definition, either before or after Shelby, for a threshold that clearly defines sufficient minority political participation, nor should there be.

This report reviews how the legal remedies used to address disparities in racial minorities’ political representation are ill-equipped to face the realities of current geography and demography, both because they are stuck in a black-white binary and because they depend on a level of geographical segregation that no longer exists. While many of the barriers that make it more difficult for people of color to vote today are similar to those that the VRA was trying to end when it was passed, there are new barriers that are subtler and often poorly discussed by the media, scholars, and policymakers alike.

When the VRA was enacted in 1965, the country had two major racial groups. Consequently, the focus of the legislation was to provide protections for African Americans against disenfranchising voting ID laws and support for the development of majority-minority districts.⁴ In the intervening years, the country’s demography has changed. Today’s America is marked by increasing racial and ethnic diversity and unprecedented levels of partisan polarization, which has heightened disputes over voting rights and changed the underlying political terrain. This is the context to consider the advent of new forms of voter suppression that are taking root in different states and cities. Accordingly, voting rights policy needs to respond, and the VRA needs to shift and expand. Voting rights policy should affirm what the right to an “effective” vote means in a diverse, and often politically polarized, society.

Between Protection and Subversion: The Shifting Role of the VRA in Empowering Voters of Color

The Supreme Court’s 2013 ruling on Shelby County V. Holder struck down the Section 4(b) coverage formula of the Voting Rights Act, essentially dismantling the preclearance mechanism created in Section 5 that required approval by either the Department of Justice or a federal court to change election laws in jurisdictions of the Jim Crow South. According to the Supreme Court, the formula used to define which states would have probable discriminatory intent was out of date after 50 years and irrelevant to the practical realities of disenfranchisement schemes. Soon after the decision was handed down, states that had previously met federal resistance were able pass new election laws without federal oversight. Immediately, new barriers to enfranchisement, particularly in communities of color, were erected.

Legendary civil rights movement activist, Senator John Lewis, lamented “This is a very sad and dark moment for our democracy.”⁵ This was a painful decision for civil rights activists. But, it was hardly a surprise. Both the courts and the government agencies that enforce the VRA had been weakening minority protections for decades.

Indeed, an assessment of the Voting Rights Act’s impact can be distilled down to the tension between trying to work as a shield for the voting rights of communities of color while simultaneously dealing with the reluctance of American jurisprudence to clearly and explicitly mete out remedies for racial discrimination.

In the decades preceding Shelby County v. Holder, Section 2 of the VRA had a number of amendments and addenda that reflected prevailing assumptions about race as a relevant and actionable form of redress for political participation. A short summary of just a few of these cases illustrates the tension between admitting how important race is to political influence and recommending race-neutral solutions to these problems that are produced by racial discrimination.

In the 1986 Thornburg v. Gingles case, the Supreme Court set forth three general preconditions for a successful Section 2 case to establish a majority-minority district, namely:⁶

• a minority group is large enough and lives closely enough together so that a relatively compact district in which the group constitutes a majority can be drawn;
• the minority group has a history of political cohesiveness or voting as a group; and
• the white majority has a history of voting as a group sufficient to usually defeat the minority group’s preferred candidate.

Once these three preconditions are met, a court then examines whether the minority group has less opportunity than other members of the electorate to influence the electoral process and to elect its candidates of choice under the “totality of circumstances.”  This effectively means that there is no clear and replicable test for determining whether those preconditions constitute a successful Section 2 claim on their own. The bar may be higher.

In the 1993 Shaw v. Reno case, the Supreme Court decided that race could not dominate the logic of redistricting, meaning that if a jurisdiction did not meet the first precondition of Thornburg, which is compactness of a racial minority in a geographic area, the Supreme Court would judge the validity of the majority-minority district with strict scrutiny.⁷ In 2006, LULAC v. Perry determined that the justification for majority-minority districts had to be decided within the context of the jurisdiction itself and not within the context of how that district would affect the overall representation of minorities in the overall state.⁸

There is no clear and replicable test for determining whether those preconditions constitute a successful Section 2 claim on their own.

Taken together, this reflects a significant change in jurisprudence. Specifically, even as the VRA protects communities of color within cases, the admissibility of race narrowed as a factor in determining how fairly drawn a jurisdiction is or is not. This moves the law away from an overall orientation toward seeing the necessity of ensuring that each vote has equal power, regardless of where it’s located in a specific state. This reorientation is especially harmful given other trends in the VRA’s implementation, which have eroded other previously existing voter protections.

As described by Jessie Rhodes in his path-breaking book Ballot Blocked, the power of the Voting Rights Act had been blunted over time.⁹ Even as Congressional Republicans reauthorized the Section 4 formula that was overturned by the Shelby decision, they consistently advocated for policies within the federal bureaucracy that narrowed the scope of the VRA. Republican presidents, for example, frequently appointed federal judges who had conservative views on voting rights and appointed officers within the Department of Justice and the Civil Rights Division who actively sought to establish bureaucratic processes that made federal statutes harder to enforce.¹⁰ Moreover, many of these changes within the administration of the legislation took place during times when low levels of national media attention were being directed toward voting rights. Clearly, the shrinking protections afforded to racial minorities is a culmination of a years-long campaign to erode the guarantees afforded by the VRA when it was first enacted.

In spite of all of this, the VRA has still been critical in terms of protecting the right to vote, even as it is intended to govern contested policy space. Since its inception, over 200 election schemes were rejected under the preclearance rules, and many more cases were adjudicated in favor of marginalized communities under the auspices of Section 2.¹¹ The problem with the contemporary focus on Section 2 since Shelby is that it places the burden of proof on the claimant rather than the jurisdiction in question. While this has negative effects for all potential claimants, it has particularly deleterious consequences for those who are new to communities. They, sadly, learn that the political rights to which they are entitled require far more of a fight than they imagined.

What the Voting Rights Act Tells Us About the Black-White Binary in Public Policymaking

A measure on the ballot in the city of Santa Clara, California, seeks to move the city from at-large to district-level elections that would be decided using ranked choice voting.¹² The suit arose from frustration due to the Santa Clara City Council having no Asian American representation, despite the city population being almost 40 percent Asian American. The challenges of creating equitable representation for Asian Americans are seen around the country in various forms. Ming Hsu Chen and Taeku Lee write in their UC Irvine Law Review article “Reimagining Democratic Inclusion: Asian Americans and the Voting Rights Act” that Asian Americans remain stubbornly and acutely underrepresented as both voters and as elected officials, well below what would be proportional for their population in the country.¹³ Relatedly, Latinx voters are subject to significant underrepresentation at the polls and in public office as well.¹⁴

Worse still, contemporary jurisprudence around the Voting Rights Act is counter-effective at helping remedy this underrepresentation. As significant media coverage is granted to the notion that we are moving toward becoming a “majority-minority” nation, the configuration of civic power shows the potential limits of there being a concomitant rise in the influence of voters of color.

As previously noted, the ability to consider race as a salient factor in the creation of voting districts is still allowed, but now under more narrowly prescribed conditions. While this approach has harmed Black political power in places where there was a high level of mobility into jurisdictions, this dictum also has severe impacts in Latinx and Asian American communities as well. This is because even as there are rapidly increasing proportions of these communities in the aggregate nationwide, they rarely constitute the majority of currently defined districts. In addition, unlike African American communities, even when there is critical mass, many of the people in these communities are immigrants and often face additional obstacles to secure their rights, especially as new arrivals who are learning the basics of voting eligibility and the terms of civic engagement.

For non-Black people of color, the current American legal infrastructure around voting actually disempowers them from reaching their full political potential. This raises a number of foundational questions that go to the heart of the Voting Rights Act’s purpose. Is the VRA designed simply to protect access to the vote itself? Or, is the VRA supposed to ensure that voters, no matter the community that they are a part of, have an equitable chance of their vote affecting their political preferences? How should VRA jurisprudence consider race, particularly in the cases of non-Black people of color for whom race does not necessarily serve as pretext for political solidarity? More to the point, with such severe underrepresentation of these groups, what type of remedy should the VRA be expected to provide in the future?

The ability to consider race as a salient factor in the creation of voting districts is still allowed, but now under more narrowly prescribed conditions.

We have evidence that the previous answers delivered by the courts have been contradictory at best and deleterious at worse to the promotion of fair political participation. LULAC v. Perry establishes that even as race is something that could be considered in the development of jurisdictions, it must not be assumed that people with similar racial backgrounds have similar cultural backgrounds. This extended the logic that was enacted in Miller v. Johnson (and also Shaw v. Reno), which ruled that majority-minority districts that used race as the “predominant” factor would be judged with strict scrutiny.¹⁵

This is troublesome because it shows that while there might be legal protection for racial minority groups that have the potential to develop majorities within a jurisdiction, there is far less in the way of protections for those communities that have substantial populations of minorities. This is because even when they are concentrated, they do not necessarily constitute the compactness prong of the Gingles test that establishes that minority communities are “communities of common interest.”¹⁶ So for communities that are rapidly growing, such as Latinx and Asian American communities, any potential gerrymandering schemes that divide up these populations are unlikely to be subject to Section 2 vote dilution claims. This has already been seen in the few Section 2 claims that Asian Americans and Latinx have filed with respect to their political influence in specific areas.

This lack of legal success highlights a deeper problem with American jurisprudence surrounding race. The claims that are successful are those that have a mandate to address issues of explicit racial discrimination. However, as the Court has ruled, racial discrimination is only legible within the context of a black-white paradigm. Those claims that hold merit are almost always in districts with an obvious scheme designed either to shrink access to the ballot box or to dilute the voting power of a critical mass of voters—and within the context of the Supreme Court, African American communities are almost exclusively the communities that have concentration rates high enough to have critical mass). Simultaneously, the Supreme Court is skeptical of making that subtext text because even as it acknowledges that the VRA was enacted in part to address historical legacies of discrimination, cases in subsequent decades have gotten further away from this mandate. With the erosion of the implementation of the law paired with the Supreme Court’s hesitation to clearly state if or how the purpose of the VRA has changed, the validity of using race as a factor in either the legitimacy or illegitimacy of electoral models is always up for grabs depending on the current composition of the Supreme Court.

This tension between the spirit of the law and how it has been implemented over time has direct and ruinous effects for Latinxs, Asian Americans, and other people of color around the country who are still in the process of growing and developing civic capacity and voice. However, as the next section shows, this tension has specific negative effects for African Americans, who in many ways are still the group that benefits most from the VRA.

As the Court has ruled, racial discrimination is only legible within the context of a black-white paradigm.

The Political Geography of VRA Enforcement

When the Voting Rights Act was passed in 1965, there was an understanding that simply protecting access to the ballot would be insufficient to ensure minority voting rights. As a corollary, Congress passed the 1967 Uniform Congressional District Act to mandate the use of single-member districts for all states with more than two seats in the House of Representatives.¹⁷ Even though most states already had single-member districts by this time, the legislation was designed to ensure that minority representation could not be undercut by at-large elections that would drown out the will of people of color, and instead allow them to live in majority-minority districts that would afford them descriptive representation or the ability to elect someone with a similar racial/cultural background. Fast forward fifty years and there is a litany of scholarship that forcefully argues that state legislatures’ attempts to “pack” and “crack” communities of color into or out of these districts reduces the communities’ overall ability to enact their will on the state more broadly.¹⁸

It is stunning that that the same structures that were used to secure the influence of communities of color can now be used to reduce that same influence. While the VRA did a major service in terms of curtailing attempts to disenfranchise voters from being able to access the ballot box, it didn’t (and couldn’t) protect against the ways that demographic shifts would make the protections that the VRA installed eventually harder to enforce.

Public policy in the United States has historically operated within the context of a black-white binary and this has undermined the democratic capacity of Asian Americans and Latinxs. However, the tension between laws that were enacted for historical redress and the policies that are used to implement them often disenfranchise the very people they were designed to support. Put another way, the black-white binary is itself anti-Black. Laws intended to alleviate damages against African Americans (as well as other people of color) are susceptible to the negative consequences of interpretation that evacuate the power of the original goal of legal restitution for discrimination in lieu of more cosmetic avenues for policy change (e.g. diversity, descriptive representation).

Shifts in the population concentrations of people of color around the country lead to different types of challenges for organizing and political representation. For African Americans this means that as populations transform and evolve, the strength of legal protections that they might have been granted under the Voting Rights Act are chipped away. The types of litigation that would be successful under a Section 2 Voting Rights Act claim in 1982 were quite broad, taking into account the specific history of a particular jurisdiction as well as using overt discrimination as a major factor in political disenfranchisement. What the standards did not do was protect against spillover effects from shifts in the county’s population. Places to which a high number of people are moving should act proactively to ensure the voting rights of new citizen configurations and, yet, the structure of the law often makes it more difficult to do so.

For African Americans this means that as populations transform and evolve, the strength of legal protections that they might have been granted under the Voting Rights Act are chipped away. 

This need for nimbleness is brought into focus when thinking about the mobility flows of African Americans. According to the 2010 U.S. Census, the Black population in the South grew from 53.6 percent to 55 percent between 2000 and 2010, while the Black population in both the Northeast and the Midwest shrank to 17 and 18 percent, respectively.¹⁹ Additional evidence suggests that two-thirds of African Americans moving from one region to another were moving to the South, and, of those African Americans moving from the Northeast, 82 percent of them were moving to the South, often moving to suburbs rather than cities.²⁰ As noted in a report by Colorlines:

The increased dispersal of black families across municipal boundaries may also impact the election of politicians most willing to address the unique concerns of black constituents. Black concentration in major cities allowed for the election of black mayors, city council members, and congressional representatives in the 1970s, 80s, and 90s. With the black population spreading beyond central city neighborhoods, will black voting power be weakened? This is of specific concern now as states are redistributing and redrawing political districts based on the Census.²¹

This type of movement has significant political consequences. As Kimberley Johnson notes, increased Black suburbanization leads to higher levels of political fragmentation, meaning that both the political compactness that often occurs as well as the “urban endowment,” such as access to national bond markets, a geographically dense network of NGOs and nonprofits, and extensive physical infrastructure, are all lost.²² Even with a higher overall number of Blacks moving to the South, their increased dispersal decreases their political power.

How does a situation arise in which a greater Black population actually leads to less political representation? The Uniform Congressional District Act determines that when there is more dispersal across a larger geographical area, only the places where there is a significant concentration of Black residents are afforded special consideration. This creates an incentive for partisan legislatures to create barriers to entry for voting because their party may benefit if they disenfranchise enough voters to help their candidate reach a plurality—as in our first-past-the-post system in which candidates are declared winners when they receive the most votes and do not need a majority.

In reality, this means that nascent and developing populations of newly arrived residents have unique challenges in developing political power because they have both the intuitive challenges of developing community as well as tremendous variation in terms of whether their right to vote will be made more or less difficult, depending on the state, and the locality within certain states, in which they reside. N’Tanya Lee, a former director of Coleman Advocates for Children and Youth, a grassroots organizing and policy advocacy organization in San Francisco, illustrates this dynamic in the Colorlines report, stating:

A black high school student goes to school in San Francisco, stays with an auntie, but their mom lives with her boyfriend in Richmond and grandma lives in Hayward. She kind of lives here; kind of doesn’t,” Lee says, painting a hypothetical picture of the instability. “What’s the anchor? Where’s the ‘home’ to organize around? Parents move to Sacramento and kids still go to school, crash with friends, or live with grandparents. Families are constantly traveling by BART and highways to visit core members of their families, who are spread out.²³

While there would be a hope that the Voting Rights Act would help to remedy the situation presented here through legal means, Section 2 actually makes it more difficult. Populations going through shifts have little in the way of legal protections against disenfranchisement schemes because the VRA, as it is applied now, primarily applies to the legality of jurisdictions, not the protection of minority voting power. Indeed, unless there are strong indications that a majority that has partisan cohesiveness as well as racial cohesiveness within a jurisdiction (remember that race cannot, by itself, be seen as the primary determinant for the creation of a majority-minority district), current case law is likely to view those approaches as illegal. This shows that while the VRA might be more effective at protecting against explicit forms of voter discrimination and electioneering, it is a much different story when it comes to supporting the development of political infrastructure (e.g. who the major political officials are, what kinds of local institutions help get out the vote, etc.). It is critical to take these questions of incorporation into account when thinking about the ways in which racial demographic and residential patterns shift and transform communities across the country.

Voting Rights: The Next Generation

How do we create a more equitable society that allows for full and fair citizenship? Through shifts in judicial interpretation and haphazard implementation, the Voting Rights Act has become an obstacle rather than a means to answer this question. That is not to say that there aren’t reforms that can strengthen the VRA. For example, some constructive proposals aim to refocus the burden of proof from the claimants back to the jurisdiction that is making a proposal that could disenfranchise a community; other ideas are to reinstate Section 5 protections with a new formula.²⁴ These would require Congress to amend the law. While certainly worthwhile, these types of reforms suffer from the longer historical trend of legal remedies, which have demonstrated potential to harm as much as they help. As long as jurisprudence does not forcefully state the importance of race in the decision-making process, there is a substantial chance that while it might help in the affected jurisdiction, it can have deleterious externalities in others. Other reforms, which would benefit from greater attention, can be achieved on the local level.

Through shifts in judicial interpretation and haphazard implementation, the Voting Rights Act has become an obstacle rather than a means to answer this question.

Focusing on strengthening civic engagement at the local level in order to empower voters has a number of benefits. There is the immediate impact of having higher levels of civic participation that can create more formal voters and the ancillary impact of making it easier for new community members to be aware of how to navigate disenfranchisement schemes as well as increased collective civic capacity in communities that have often proved successful in overcoming the nefarious aims of electioneering that seeks to weaken political power. Similar to making changes directly to the Voting Rights Act, the following recommendations are not easy, but they have all shown relative success where they have been tried and could have dramatic effects, if implemented at scale, in terms of creating a more diverse, equitable, and accountable electorate nationwide.

Develop Public Engagement Units (PEU) in Cities Around the Country

In 2015, New York City developed an innovative outreach team to make sure that citizens had access to social services that they were entitled to receive, such as rental subsidies, health care enrollment, and free legal assistance if they were at risk of eviction from their homes.²⁵ The Public Engagement United (PEU) helped develop a level of trust in public assistance, as well as a development of civic infrastructure, that focused specifically on hard-to-reach constituents. In Minnesota, there is a Civic Engagement Committee that has been designed for what they term “meaningful engagement” to empower citizens across the state in ways that have the distinct impact of developing trust and participation in government.²⁶ By having civic engagement centered within the public policy of cities and municipalities, there are a number of districts that can still develop strong, cogent blocs of power that bring representation of people of color much closer to equity within those locations.

Merge Redistricting Commissions with Community Outreach Programs

Thirteen states have independent redistricting commissions that attempt to get away from the partisan incentives that structure the gerrymandering of state legislatures around the country. This approach tries to elevate the voices of people who have an objective perspective on how communities and their political jurisdictions are organized.²⁷ It is designed as an alternative to election commissions, which are split along partisan lines—often in odd-numbered configurations with the majority of seats designated to the party holding a majority of seats in the state legislature). However, in practice, partisan divisions replicate themselves at this level, meaning that while the pace at which gerrymandered districts change is faster, the results are often very similar to states where the legislature have the responsibility for drawing the lines. A way to get closer to the goal of equitable representation would be to center civic equity through actively factoring in the effects of civic participation on the development of these districts. Thinking about how to develop participation for all constituents rather than those who happen to be in the racial and partisan majority would make it more difficult for parties to file claims against communities of color for having “too much” power because parties would then have to address the fact that it was both an independent and bipartisan set of actors that set up the boundaries.

Enact Proportional Representation Around the Country

This is likely the largest change but perhaps the one with the most promise in the contemporary moment. The pending Santa Clara case is instructive because the remedy proposed moves the city to a proportional representation system in which the Asian American residents might be able to control a portion of the seats in the County Council relative to their population density within the city.²⁸ Alternative voting systems, such as ranked choice voting, have taken root in sporadic, yet impactful, ways around the country. While the merits of using this type of voting system over the first-past-the-post system that we currently have at the federal level will not be discussed here, what is critical to note is how first-past-the-post exacerbates the incentives to disenfranchise communities of color.²⁹ As noted by Lee Drutman, “Under a proportional system, if you want to live in a big, liberal city in a liberal state, you don’t give up the chance to make a difference with your vote. There is also very little possibility for consequential gerrymandering in proportional representation systems, since districts tend to be so big that there’s not much to gain from alternative line-drawings.”³⁰

While Drutman primarily proposes that we have proportional representation at the federal level, it may be best to start at the state and local level. For one, it allows people to take greater ownership over their local communities, which is especially helpful for political incorporation purposes, and it creates an awareness of the system, which is currently stymied by the muscularity of the two parties at the federal level.³¹ Starting at the local level is critical because it helps build the civic infrastructure that allows for upstream impacts in terms of political engagement and capacity for organizing. The nationalization of two-party politics creates the perception that the local level of politics has a smaller and smaller role in the calculation of why people enter politics. Given what we know about geographic inequities and the impact of public policy on political empowerment, this is not the case. It is the case that the protections that are absent from the Voting Rights Act, if they will not be addressed by the courts, are not going to be addressed by Congress either. What can happen is a deeper investment in local communities that seeks to work around these issues in ways that directly and impactfully empower communities of color.

The nationalization of two-party politics creates the perception that the local level of politics has a smaller and smaller role in the calculation of why people enter politics. 

The purpose of the Voting Rights Act at the time of its passage was to protect access to the ballot by African Americans. A second generation of rights, established through Allen V. State Board of Elections and other subsequent cases, were centered around the right to fair and equal representation and an “undiluted” vote.³² To be sure, assaults against these first two generations of voting rights are still with us, particularly in a post-Shelby world. Election times are being cut, there are new, onerous identification requirements popping up in different parts of the country, and some states (southern states in particular) are being gerrymandered in ways that make it harder for people of color’s votes to have the same outcome that they would in other districts that were drawn with equal representation in mind. Because of these enduring struggles, it is important to note just how important the Voting Rights Act still is to this day.

However, there is a new landscape on which the battles for equitable influence and representation are being waged. For those communities that are growing but do not yet have the numbers to establish majority-minority districts around the country, they do not have the legal assurances that their votes will matter in the same ways as their white counterparts’. For those people who are moving back to regions previously covered by Section 5, which should still be covered by Section 2 of the VRA, the increased dispersal associated with American suburbanization actually makes it harder to access the type of civic power that might be expected by moving to states with higher levels of similarly situated residents. One issue not addressed here is how this relates to the displacement caused by gentrification.³³ The “spillover” suburbs that capture those who have been displaced as a result of rising housing costs in highly concentrated urban areas suffer from the same type of civic disinvestment that is seen by those who actively look for better financial opportunities as a result of reverse migration. The intersection of legal protections and political incorporation of new community arrivals constitutes a new generation of voting rights struggles. Emplacing the local and investing in new generations of communities can lead to new models of policy change designed to meet these struggles and those that will meet generations in the future.

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Christian Hosam is a 2017-18 Millennial Fellow with the Political Reform program at New America. He would like to thank the entire Political Reform team, particularly Lee Drutman and Mark Schmitt, for their help in framing, refining, and elevating the ideas presented in his paper. Thanks are also due to Marcia Chatelain, Rachel Black, and Didi Kuo for their insightful edits and comments. Special thanks to Ted Johnson, Myrna Pérez, Janelle Wong, Kareem Crayton, and Yamil Velez for their helpful thoughts and feedback. Finally, many thanks to the other Millennial Public Policy Fellows, Reid Cramer, and Melody Frierson for their support during this fellowship year.