Barely had the Court issued its opinion in the Shelby County, Alabama v. Holder, invalidating Section 4 of the Voting Rights Act and for all practical purposes Section 5, when the State of Texas promptly announced a new photo ID requirement. And the Court’s reasoning in this and other cases in recent years, including the freshly minted Arizona v. Inter Tribal Council of Arizona, 570 U.S. ____(2013), leaves little doubt that it is emboldening states to proceed on the path of the last few years, imposing ID and other limitations on access to the polls.