state's Congressional representation on the basis of the Amendment. Bonfield, writing in 1960, suggested that "[t]he hot political nature of such proposals has doomed them to failure." Aided by this lack of enforcement, southern states continued to use pretexts to prevent many blacks from voting until the passage of the Voting Rights Act of 1965. In the Fourth Circuit case of Saunders v Wilkins (1945), Saunders claimed that Virginia should have its Congressional representation reduced because of its use of a poll tax and other voting restrictions. The plaintiff sued for the right to run for Congress at large in the state, rather than in one of its designated Congressional districts. The lawsuit was dismissed as a political question. Influence on voting rights Some have argued that Section 2 was implicitly repealed by the Fifteenth Amendment, but the Supreme Court acknowledged Section2 in later decisions. In Minor v. Happersett (1875), the Supreme Court cited Section2 as supporting its conclusion that the right to vote was not among the "privileges and immunities of citizenship" protected by Section 1. Women would not achieve equal voting rights throughout the United States until the adoption of Nineteenth Amendment in 1920. In Richardson v. Ramirez (1974), the Court cited Section2 in holding that Section 1's Equal Protection Clause does not prohibit states disenfranchising felons. In Hunter v. Underwood (1985), a case involving disenfranchising black misdemeanants, the Supreme Court concluded that the Tenth Amendment cannot save legislation prohibited by the subsequently enacted Fourteenth Amendment. More specifically the Court concluded that laws passed with a discriminatory purpose are not excepted from the operation of the Equal Protection Clause by the "other crime" provision of Section 2. The Court held that Section2 "was not designed to permit the purposeful racial discrimination [...] which otherwise violates [Section]1 of the Fourteenth Amendment." Criticism Abolitionist leaders criticized the amendment's failure to specifically prohibit the states from denying people the right to vote on the basis of race. Section 2 protects the right to vote only of adult males, not adult females, making it the only provision of the Constitution to explicitly discriminate on the basis of sex. Section2 was condemned by women's suffragists, such as Elizabeth Cady Stanton and Susan B. Anthony, who had long seen their cause as linked to that of black rights. The separation of black civil rights from women's civil rights split the two movements for decades.