opinion allowed for multiple interpreters of the Fourteenth Amendment, as opposed to just that of the judiciary. In dissent, Justice Harlan criticized the "ratchet theory" and the idea of multiple interpreters of the 14th Amendment. Harlan relied on the separation of powers doctrine to argue that allowing Congress to interpret the 14th Amendment undercut the power of the judiciary. He objected to Congress having the power to interpret the 14th Amendment substantively (to create new rights). Harlan argued that the appropriate use of Section 5 power was the enforcement of judicially-recognized 14th Amendment rights. Significance Katzenbach v. Morgan is a prime example of judicial deference to Congressional authority. It allowed Congress great latitude in use of Section 5. The Supreme Court, 31 years after Katzenbach, revisited the "ratchet" interpretation, in the case of City of Boerne v. Flores (1997) and stated, "This is not a necessary interpretation, however, or even the best one." By striking down the state application of the Religious Freedom Restoration Act of 1993, it addressed the separation of powers concerns that had been voiced earlier by Harlan. See also List of United States Supreme Court cases, volume 384 Further reading External links United States Supreme Court cases United States equal protection case law United States elections case law 1966 in United States case law Legal history of New York (state) Puerto Rican diaspora History of voting rights in the United States Political history of New York City United States Supreme Court cases of the Warren Court