By: Ally Lichtman ‘29
Volume XI – Issue I – Fall 2025
I. INTRODUCTION
On June 22, 1970, President Richard Nixon signed the first set of amendments to the Voting Rights Act of 1965, reauthorizing and expanding its protections against discriminatory voting practices. Critically, he issued a signing statement questioning Congress’s authority to enact Title III, which lowered the voting age to 18 in all elections. [1] Previously, states reserved the power to set their minimum voting requirements, most often at 21 years of age. Nixon’s statement, although not legally binding, foreshadowed that the voting age provision would face constitutional review. [2] The Supreme Court of the United States ruled in Oregon v. Mitchell, 400 U.S. 112 (1970), that Congress has the authority to regulate voting age qualifications for national but not state and local elections. [3] In response, Congress proposed an amendment to the U.S. Constitution establishing a national minimum voting age, and the state legislatures ratified the resulting 26th Amendment on July 1, 1971. [4] Thus, within a year, all three branches of the federal government and the state legislatures participated in the political and legal process of lowering the voting age to 18.
The path to the 26th Amendment reveals the dynamics of social change, the role of federalism in election law, and the complex relationship between the judiciary and legislature. Although there is no clear framework for litigating the 26th Amendment, it has significant implications for youth participation and the expanded electorate today. Therefore, courts should adopt a uniform standard for interpreting legal claims in order to protect citizens against voting rights violations consistently. This article first discusses the legal history of voter qualifications in the United States and the public mobilization that pressured Congress to lower the voting age. Next, it examines the nuances of the Supreme Court’s ruling in Oregon v. Mitchell and its reversal in part via the constitutional amendment process. Finally, this article analyzes the current status of litigation under the 26th Amendment and recommends judicial and legislative reforms to fill the gaps in implementation. Indeed, revisiting the 26th Amendment is a necessary step to realize the fundamental right to vote in the 21st century.
II. BACKGROUND
i. Legal History
The U.S. Constitution does not establish a positive right to vote. During the century after ratification in 1787, three main constitutional provisions governed voting practices: Article I, Section 2, Clause 1 (Qualifications); Article I, Section 4, Clause 1 (Elections); and Article II, Section 1, Clause 2 (Electors). The Voter Qualifications Clause requires that eligibility to vote in congressional elections matches the requirements of the “most numerous Branch of the State Legislature” or the lower house. [5] The Constitution thus reserves the power to determine voter qualifications to the states, excluding the subsequent 15th, 19th, 24th, and 26th Amendments. The Elections Clause holds that state legislatures are responsible for determining the “time, place, and manner” of elections for Senators and Representatives, but Congress retains the authority to “make or alter such Regulations” as necessary. [6] The Electors Appointment Clause also provides that states choose electors to vote for presidential candidates through the Electoral College. [7] Combined, these provisions give states vast control over election administration.
In the realm of voter qualifications, early state laws and constitutions restricted voting rights to property-owning white men over the age of 21, as defined in English common law. [8] Section 2 of the 14th Amendment stipulated that if states denied the right to vote to male citizens over age 21, their congressional representation would be reduced. [9] In effect, Section 2 of the 14th Amendment institutionalized the minimum age requirement from its ratification in 1868 until the Voting Rights Act Amendments of 1970.
ii. Dynamics of Social Change
Voting age emerged as a subject of debate in the mid-20th century, when the U.S. entered three conflicts that decisively shaped public opinion: World War II, the Korean War, and the Vietnam War. In 1942, the increasing demands of U.S. involvement in World War II prompted Congress to amend the Selective Training and Service Act of 1940, requiring men as young as 18 to register with the Selective Service System for potential conscription. [10] The reality that young soldiers fought on the front lines yet could not elect their representatives, who approved the declaration of war, generated public criticism. For example, First Lady Eleanor Roosevelt reasoned that men who “fight their country’s battles” also deserve to be “full citizens with voting powers.” [11]
In response, Congress included a voting age provision in Title III of the Voting Rights Act Amendments of 1970. The bill extended the Voting Rights Act of 1965 and added three protections under Sections 201, 202, and 302, respectively: 1) the suspension of literacy tests for all elections; 2) the abolishment of state residency requirements and establishment of absentee registration standards in presidential and vice presidential elections; and 3) the lowering of the minimum voting age to 18 in federal, state, and local elections. [12] Congress declared that the previous voting age of 21 constituted “unfair treatment” of 18- to 21-year-old citizens given their expanded “national defense responsibilities.” [13] However, after the bill passed Congress, President Nixon signed the Voting Rights Act Amendments of 1970 into law with reservations about the constitutionality of Title III. He cautioned in his signing statement that “Congress has no power to enact it by simple statute, but rather it requires a constitutional amendment.” [14] Six months later, the Supreme Court stepped in to consider this core question in Oregon v. Mitchell.
III. OREGON V. MITCHELL (1970): FEDERALISM AND ELECTION LAW
i. Facts
The states of Oregon, Texas, Arizona, and Idaho filed lawsuits challenging the constitutionality of Sections 201, 202, and 302 of the federal Voting Rights Act Amendments of 1970. [15] The Supreme Court was the first to hear Oregon v. Mitchell per its original jurisdiction over the case, as it involved a dispute between states and the federal government. [16] The Court considered each section independently; however, this paper will focus on the debate over the voting age provision. Section 302, if upheld, would effectively override conflicting state laws setting age qualifications. Oregon specifically sought an injunction against the enforcement of Section 302 to retain the minimum voting age of 21 outlined in its state constitution. [17]
ii. Holding
In a 5-4 decision, the Court ruled that Title III was valid in federal but not state and local elections. Justice Hugo Black issued the plurality opinion, and Justices William Douglas, John Harlan, William Brennan, and Potter Stewart wrote opinions concurring and dissenting in part with different reasoning. [18] Justice Black grounded Congress’s authority to regulate the voting age for federal elections in Article I, Section 4; Article II, Section 1; and Article I, Section 8, Clause 18 (Necessary and Proper). These three provisions reinforce that while states are primarily responsible for setting voter qualifications, Congress retains the ultimate power over its own laws, including federal elections. By contrast, Congress’s attempt to set the voting age in state and local elections interfered with Article I, Section 2, which reserved the exclusive power over voter qualifications to the states. In Justice Black’s view, allowing Congress to determine the qualifications for all voters would “under the guise of insuring equal protection, blot out all state power, leaving the 50 States as little more than impotent figureheads.” [19] Title III was thus invalid for state and local elections as it exceeded the congressional enforcement power outlined in the Constitution. This plurality opinion clearly delineated the boundaries of federal and state power over election law.
iii. Concurring and Dissenting, In Part
While Justice Black held that Articles I and II only authorized Congress to lower the voting age at the federal level, Justice Douglas declared that Section 302 was constitutional in all elections. He reasoned that 18- to 21-year-old citizens are entitled to equal voting rights under the Equal Protection Clause and Section 5 of the 14th Amendment, which grants Congress the power of enforcement by “appropriate legislation.” [20] The Equal Protection Clause, according to Justice Douglas, extends beyond racial discrimination to other classifications. Congress specifically cited the “unfair treatment” of young citizens who had a stake but no say in the democratic process, violating the equal protection of the laws based on age. [21] In a separate dissent, Justice Brennan added that states did not have a legitimate interest in denying the franchise to citizens between 18 and 21 years old because they were not less capable, responsible, or intelligent than other adults, as evidenced by state laws on marriage and education. [22] From this lens, Section 302 was constitutional and enforceable at the federal, state, and local levels.
On the other hand, Justice Harlan dissented that Congress lacks the authority to set the minimum voting age for any elections. In an extended discussion of the historical context in 1868, he concluded that the 14th Amendment did not limit state control. State legislatures retained the power to establish voter qualifications, and Congress’s simple “factfinding” judgment in favor of extending the franchise was insufficient to trigger judicial protection. [23] Separately, Justice Stewart noted that Justice Douglas’s and Brennan’s reliance on the Equal Protection Clause implicates the strict scrutiny test, which would require the state government to show that a law is “narrowly tailored to serve a compelling government interest.” [24] Yet, it would be impossible for a state to demonstrate a compelling interest in assigning a minimum age requirement. [25] The Court thus could not reasonably empower Congress to lower the voting age on equal protection grounds. In this view, Article I, Article II, and the Equal Protection Clause invalidated Section 302 in its entirety.
iv. Significance
The concurrences and dissents in part to Oregon v. Mitchell revealed substantial divisions among the Justices in their interpretation of federal and state control over election law. Justices Douglas and Brennan read an expansive view of federal power, while Justices Harlan and Stewart viewed voter qualifications as within the sole purview of state governments. Justice Black took the middle ground, lowering the voting age to 18 at the federal but not state and local levels. [26] This had immediate practical implications for election administration, as each state could not feasibly lower its voting age to match the federal standard prior to the 1972 presidential election. The ruling left Congress two options: 1) manage a dual-age voting system, or 2) propose a constitutional amendment and obtain state ratification. [27]
IV. REVERSAL IN PART: JUDICIARY TO LEGISLATURE
i. Proposal and Ratification
As Nixon predicted in his signing statement to the Voting Rights Act Amendments of 1970, Congress used the Article V amendment process to reconcile the federal and state voting age gap and establish a uniform national standard after the Court’s ruling in Oregon v. Mitchell. In the congressional floor debates, proponents reiterated that the maturity and responsibility of young citizens entitled them to equal voting rights. [28] More importantly, the infeasibility of adopting and maintaining two sets of voter lists produced exigency that swiftly advanced the passage of the 26th Amendment. The Amendment earned the approval of two-thirds of the House and Senate and ratification by three-fourths of the state legislatures in a record three months after its initial proposal in January 1971. [29]
ii. Significance
The passage of the 26th Amendment was legally significant for two main reasons. First, it constituted one of only five constitutional amendments that had the effect of reversing a prior Supreme Court ruling. This interaction embodies the complex relationship between the judiciary and legislature in the U.S. system of checks and balances, wherein Congress and the states have the ultimate constitutional authority to correct an unjust or unworkable Court decision. Second, as Representative Richard Poff of Virginia interpreted in the House debates, the language of the 26th Amendment was substantively different from that of Title III. [30]
While Title III simply lowered the voting age to eighteen, the 26th Amendment also required that the vote “shall not be denied or abridged” based on age. This distinct language mirrors the 15th and 19th Amendments, which extended the franchise to Black men and women, respectively. Congress intended to give the courts broad power to protect all voters over 18 years of age when laws infringe on their 26th Amendment rights. The ensuing litigation from 1971 to the present exhibits the widening scope of the Amendment in the contemporary election landscape.
V. LITIGATION AND IMPLICATIONS
i. Framework
Litigation over the 26th Amendment has taken place almost exclusively in lower courts. [31] The primary areas of contention include residency and voter identification requirements, as well as absentee and early voting opportunities, both for college students and the elderly. The courts have not yet agreed on a consistent standard to interpret the 26th Amendment, but judges have recently applied the existing Arlington Heights and Anderson-Burdick frameworks. [32] The Arlington Heights framework emerged from a constitutional challenge to racially discriminatory rezoning in Village of Arlington Heights v. Metropolitan Housing Development Corp. To invalidate a law under this test, plaintiffs must prove discriminatory purpose based on five factors: impact, historical background, sequence of events, departures from the norm, and history of the action. [33]
The Anderson-Burdick framework arose from a challenge to an early filing deadline for independent presidential candidates in Anderson v. Celebrezze and a prohibition on write-in voting in Burdick v. Takushi. [34] This balancing test asks courts to weigh the burden on the right to vote against the legitimacy of the state’s interests. Anderson-Burdick is a more flexible standard than Arlington Heights, as it triggers strict scrutiny only for “severe” restrictions but generally permits “reasonable, nondiscriminatory” ones. [35] Importantly, it offers protection against laws that have a disparate impact on a particular group of voters, even without overt evidence of disparate treatment. [36]
ii. Case Studies
League of Women Voters of Florida v. Detzner applied the Arlington Heights intentional discrimination standard to early voting for college students. In May 2013, Florida Governor Rick Scott signed Florida Statute § 101.657, known as the Early Voting Statute, into law, which authorized election supervisors to designate early voting sites. The Secretary of State, Detzner, subsequently issued an advisory opinion excluding college and university campuses from the list of eligible locations. The League of Women Voters filed suit, arguing that the advisory opinion abridged the rights of college students who were categorically denied access to convenient early voting opportunities on campus. The Florida Northern District Court granted a preliminary injunction against the Early Voting Statute based on the 26th Amendment’s expanded protections for voting rights. Indeed, the district court rejected the Anderson-Burdick balancing test, which implies that the 26th Amendment “contributes no added protection” for young voters beyond the 14th Amendment. It relied instead on the stricter Arlington Heights standard, reasoning that the advisory opinion was “unexplainable on grounds other than age” and thus revealed a discriminatory purpose. [37] League of Women Voters of Florida serves as a model to litigate future claims with clear evidence of intentional discrimination against a group of voters.
Texas Democratic Party v. Abbott clarified the proper application of the Anderson-Burdick balancing test to the 26th Amendment. In March 2020, the Texas Democratic Party contested that Texas Election Code § 82.003 violated the 26th Amendment as it allowed only individuals over the age of 65 to vote absentee without excuse during the COVID-19 pandemic. The District Court for the Western District of Texas agreed that the law burdened young voters without a legitimate state interest according to the Anderson-Burdick standard. However, the Fifth Circuit Court of Appeals reversed the district court’s holding, reasoning that “conferring a privilege on one category of voters” does not “deny or abridge” the franchise to those without that privilege. In this instance, Texas Election Code § 82.003 expanded voting access for the elderly without diminishing the 26th Amendment rights of other age groups. [38] Texas Democratic Party illustrates the broad scope of the 26th Amendment protections and guides the use of Anderson-Burdick in future cases.
iii. Potential Solutions
The judiciary and Congress should leverage both sections of the 26th Amendment to protect the franchise for people of all ages in the 21st century. First, a broad reading of the 26th Amendment invalidates voting laws that either intentionally discriminate based on age or disproportionately burden a particular age group. [39] Arlington Heights and Anderson-Burdick independently guide judicial interpretation of the 26th Amendment, but a uniform standard is critical to ensure consistent rulings that remedy abridgments of the right to vote on both accounts. Constitutional rights attorney Yael Bromberg has proposed a framework that would allow plaintiffs to show a violation of their rights through prima facie “on its face” discrimination, disparate treatment in Arlington Heights, or disparate impact in Anderson-Burdick. [40] The courts have previously viewed these tests as mutually exclusive or even contradictory in their interpretation of 26th Amendment claims. However, a hybrid approach would yield “heightened constitutionalism” protecting voters under both the 14th and 26th Amendments. Indeed, Bromberg emphasizes that the right to vote is not a “zero-sum game.” [41] In practice, this model would provide a clear basis for litigation and increase the predictability of outcomes. Consistent judicial interpretation is essential to advance challenges to discriminatory laws and effectively safeguard voting rights under the 26th Amendment.
In addition, Congress should enact federal laws to remove the ongoing barriers to youth voter access exemplified in League of Women Voters of Florida and Texas Democratic Party. Ratification was the necessary first step, but “appropriate legislation” must follow to enforce the 26th Amendment. [42] The For the People Act, passed by the House in 2021, aims to expand automatic and same-day registration as well as early and absentee voting. It also outlines a program to educate high school students about voter registration and authorizes minors to submit voter registration applications. [43] The Youth Voting Rights Act, introduced in the Senate in 2023, sets forth additional measures to promote youth participation in the electoral process. For example, it would treat public institutions of higher education as voter registration agencies, require states to implement pre-registration for minors over the age of 16, guarantee polling sites on college and university campuses, and classify student identification cards as voter identification. [44] The Act establishes federal guidelines and relies on states and localities for implementation, consistent with the decentralized structure of the U.S. election system.
In fact, the expansion of the electorate and increase in youth participation have occurred most successfully at the grassroots level. The 26th Amendment sets the floor, not the ceiling; state constitutional amendments and statutes have extended the franchise below the minimum age of 18. [45] In 2013, the city of Takoma Park, Maryland, passed legislation that permitted 16- and 17-year-olds to vote in local elections; in 2016, Berkeley, California, followed with school board elections. [46] The movement has spread across the U.S. and recently motivated proposals to lower the voting age to 16 at the federal level. [47] As with the historic path to the 26th Amendment, youth advocates have steered the initiative. Most notably, Vote16USA, founded in 2015, connects youth to state campaigns and organizers nationwide. [48] Local movements are essential to build momentum, garner public consensus, and ultimately achieve legislative change, linking the social, political, and legal components of voting reform.
VI. CONCLUSION
Fifty years after the ratification of the 26th Amendment, significant practical and legal barriers to the ballot persist and demand fundamental change. Restrictive state voting laws often have a disproportionate effect on young and elderly voters, and the enforcement power in Section 2 provides a clear legal remedy. [49] Yet, judicial interpretation of the 26th Amendment is narrow and inconsistent, and federal voting rights law remains limited and underenforced. [50] It is therefore necessary for both the courts and Congress to take action to redress the denial and abridgment of the right to vote. Courts should formally adopt a legal framework that encompasses the criteria in Arlington Heights and Anderson-Burdick, granting both uniformity and flexibility to judges in their analysis of 26th Amendment claims. In addition, federal laws, including the For the People Act and Youth Voting Rights Act, are crucial to empower broad voter participation nationwide. This two-pronged approach operates within the unique framework of U.S. federalism in election administration and leverages the dynamic interbranch relations that characterize voting reform. The 1971 constitutional extension of the franchise to citizens over the age of 18 alone was insufficient. The time has come to guarantee equal access to the ballot by age in the spirit of the democratic process that first won the struggle for the 26th Amendment.
Endnotes
[1] 84 U.S.C. § 314, 318 (1971), https://www.congress.gov/bill/91st-congress/house-bill/4249/text.
[2] Richard Nixon, “Statement on Signing the Voting Rights Act Amendments of 1970,” The American Presidency Project, June 22, 1970, https://www.presidency.ucsb.edu/documents/statement-signing-the-voting-rights-actamendments-1970.
[3] Oregon v. Mitchell, 410 U.S. 112, 112 (1970), https://tile.loc.gov/storage-services/service/ll/usrep/usrep400/ usrep400112/usrep400112.pdf.
[4] “Ratification of the Twenty-Sixth Amendment,” Legal Information Institute, accessed October 29, 2025, https://www.law.cornell.edu/constitution-conan/amendment-26/ratification-of-the-twenty-sixth-amendment.
[5] “Voter Qualifications for House of Representatives Elections,” Constitution Annotated, accessed October 18, 2025, https://constitution.congress.gov/browse/article-1/section-2/.
[6] “Congress and Elections Clause,” Constitution Annotated, accessed October 18, 2025, https://constitution.congress.gov/browse/article-1/section-4/.
[7] “Overview of Electors Appointment Clause,” Constitution Annotated, accessed October 18, 2025, https://constitution.congress.gov/browse/article-2/section-1/clause-2/.
[8] “Voter Age Qualifications in the Early United States,” Constitution Annotated, accessed October 29, 2025, https://www.law.cornell.edu/constitution-conan/amendment-26/voter-age-qualifications-in-the-early-united-states.
[9] “Overview of Apportionment of Representation,” Constitution Annotated, accessed November 1, 2025, https://constitution.congress.gov/browse/amendment-14/section-2/.
[10] 56 U.S.C. § 1018, 661 (1942), https://tile.loc.gov/storage-services/service/ll/uscode/uscode1940-00605/ uscode1940-006050a003/uscode1940-006050a003.pdf.
[11] Eleanor Roosevelt, “My Day,” The Eleanor Roosevelt Newspapers Digital Edition, January 21, 1943, https://www2.gwu.edu/~erpapers/myday/displaydoc.cfm?_y=1943&_f=md056400.
[12] 84 U.S.C. § 314, 314.
[13] 84 U.S.C. § 314, 318.
[14] Nixon, “Statement on Signing.”
[15] Oregon, 410 U.S. 112, 112.
[16] “Original Jurisdiction,” Legal Information Institute, accessed November 14, 2025, https://www.law.cornell.edu/ wex/original_jurisdiction.
[17] Oregon, 410 U.S. 112, 227.
[18] Oregon, 410 U.S. 112, 118.
[19] Oregon, 410 U.S. 112, 126.
[20] Oregon, 410 U.S. 112, 113.
[21] 84 U.S.C. § 314, 318.
[22] Oregon, 410 U.S. 112, 280.
[23] Oregon, 410 U.S. 112, 207.
[24] April J. Anderson, “Equal Protection: Strict Scrutiny of Racial Classifications,” Congressional Research Service, June 30, 2023, https://www.congress.gov/crs-product/IF12391.
[25] Oregon, 410 U.S. 112, 294.
[26] Eric S. Fish, “The Twenty-Sixth Amendment Enforcement Power,” The Yale Law Journal 121, no. 5 (March 2012): 1193, https://www.jstor.org/stable/41509914.
[27] “Proposal of the Twenty-Sixth Amendment: Introduction and Committee Action,” Legal Information Institute, accessed October 18, 2025, https://www.law.cornell.edu/constitution-conan/amendment-26/proposal-of-the-twentysixth-amendment-introduction-and-committee-action.
[28] “Proposal of the Twenty-Sixth Amendment: Congressional Floor Debates and Final Passage,” Legal Information Institute, accessed October 18, 2025, https://www.law.cornell.edu/constitution-conan/amendment-26/proposal-ofthe-twenty-sixth-amendment-congressional-floor-debates-and-final-passage.
[29] “Ratification of the Twenty-Sixth Amendment,” Legal Information Institute, accessed November 4, 2025, https://www.law.cornell.edu/constitution-conan/amendment-26/ratification-of-the-twenty-sixth-amendment.
[30] “Proposal of the Twenty-Sixth Amendment: Congressional Floor Debates and Final Passage.”
[31] “The Scope of the Twenty-Sixth Amendment,” Legal Information Institute, accessed October 18, 2025, https://www.law.cornell.edu/constitution-conan/amendment-26/the-scope-of-the-twenty-sixth-amendment.
[32] Alison Ge, “The Twenty-Sixth Amendment and Protecting the Right to Vote,” N.Y.U. Journal of Legislation and Public Policy 25, no. 167 (February 2023): 171, https://nyujlpp.org/wp-content/uploads/2023/04/JLPP-25.1-Ge.pdf.
[33] Village of Arlington Heights v. Metropolitan Housing Development Corporation, 429 U.S. 252, 253 (1977), https://tile.loc.gov/storage-services/service/ll/usrep/usrep429/usrep429252/usrep429252.pdf.
[34] Anderson v. Celebrezze, 460 U.S. 780, 780 (1983), https://tile.loc.gov/storage-services/service/ll/usrep/usrep460/ usrep460780/usrep460780.pdf.
[35] Burdick v. Takushi, 504 U.S. 428, 434 (1992), https://tile.loc.gov/storage-services/service/ll/usrep/usrep504/ usrep504428/usrep504428.pdf.
[36] April J. Anderson, “What Is Disparate-Impact Discrimination?,” Congressional Research Service, July 9, 2025, https://www.congress.gov/crs-product/IF13057.
[37] League of Women Voters of Fla., Inc. v. Detzner, 314 F. Supp. 3d 1205, 31 (N.D. Fla. 2018), https://law.justia.com/cases/federal/district-courts/florida/flndce/4:2018cv00251/98583/65/.
[38] Texas Democratic Party v. Abbott, 978 F.3d 168, 34 (5th Circ. 2020), https://law.justia.com/cases/federal/ appellate-courts/ca5/20-50407/20-50407-2020-10-14.html.
[39] Eric S. Fish, “The Twenty-Sixth Amendment Enforcement Power,” 1172.
[40] Yael Bromberg, “Youth Voting Rights and the Unfulfilled Promise of the Twenty-Sixth Amendment,” University of Pennsylvania Journal of Constitutional Law 21, no. 5 (May 2019): 1164, https://scholarship.law.upenn.edu/cgi/ viewcontent.cgi?article=1697&context=jcl.
[41] Bromberg, “Youth Voting Rights,” 1166.
[42] “Twenty-Sixth Amendment.”
[43] H.R.1, Congress.gov, January 4, 2021, https://www.congress.gov/bill/117th-congress/house-bill/1.
[44] S.2985, Congress.gov, September 28, 2023, https://www.congress.gov/bill/118th-congress/senate-bill/2985.
[45] Bromberg, “Youth Voting Rights,” 1105.
[46] Joshua A. Douglas, “Lowering the Voting Age from the Ground Up: The United States’ Experience in Allowing 16-Year Olds to Vote,” in Lowering the Voting Age to 16, ed. Jan Eichhorn and Johannes Bergh (Palgrave Macmillan, 2020), 211, https://doi.org/10.1007/978-3-030-32541-1_11.
[47] H.J.Res.16, Congress.gov, January 11, 2023, https://www.congress.gov/bill/118th-congress/ house-joint-resolution/16.
[48] Generation Citizen, “Young Voices at the Ballot Box: Lowering the Voting Age for Local Elections in 2017 and Beyond,” National Civic Review 106, no. 2 (Summer 2017): 29, https://www.jstor.org/stable/10.1002/naticivirevi. 106.2.0029.
[49] “Twenty-Sixth Amendment.”
[50] Franita Tolson, “The Elections Clause and the Underenforcement of Federal Law,” The Yale Law Journal Forum 129 (November 2019): 173, https://yalelawjournal.org/essay/the-elections-clause-and-the-underenforcement-offederal-law.