John Gear writes:

System failure, the same problem that led a Court to issue desegregation decisions such as Brown v. Bd. of Ed., which is just as much (if not more) of an overreach since public education is not mentioned anywhere in the Constitution, whereas voting rights permeates it.

And since this Court is hot on strict construction, we could also argue for a revival of the Guaranty Clause (Art. IV, Sec. 4), since it is only patent judicial activism that says it is meaningless.  (If the 10th A. can be revived, why not the Guaranty Clause?)

John Gear, J.D.
"The large print giveth and the small print taketh away" -- Tom Waits