Voting Rights Act of 1965
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. However, despite lobbying from civil rights leaders, the Act did not prohibit most forms of voting discrimination. 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". 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.
Antipornography Civil Rights Ordinance
In spite of the defeat in the courts, Dworkin, MacKinnon, and some other feminists continued to advocate versions of the civil rights ordinance, organizing campaigns to place it on the ballot as a voter initiative in Cambridge, Massachusetts in 1985 (where it was voted down in the referendum 58%–42%), and then again in Bellingham, Washington in 1988 (where it was passed). The American Civil Liberties Union filed suit against the city of Bellingham after the ordinance was passed, and the federal court again struck the law down on First Amendment grounds.