in the district have been overwhelmingly won by the Democratic Party. The Democrats' support of increased D.C. representation in Congress and the Republicans' opposition to it have been alleged to be purely for self-serving reasons. Human rights Since 2006, the United Nations Human Rights Committee report has cited the United States for denying D.C. residents voting rights in violation of the International Covenant on Civil and Political Rights, a treaty the United States ratified in 1992. In 2015, D.C. became a member of the Unrepresented Nations and Peoples Organization. Proposed reforms Advocates for D.C. voting rights have proposed several competing reforms to increase the District's representation in Congress. These proposals generally involve either treating D.C. more like a state or allowing Maryland to take back the land it ceded to form the District. Legislation Several bills have been introduced in Congress to grant the District of Columbia voting representation in one or both houses of Congress. The constitutional argument about whether Congress can provide the District of Columbia with a voting member in the House of Representatives, but not in the Senate, is heavily debated by each side. In Hepburn v. Ellzey (1805), the Supreme Court held that the right of residents of the District to sue residents of other states is not explicitly stated in Article III, Section 2. In National Mutual Insurance Co. v. Tidewater Transfer Co., Inc, , the Supreme Court held that Congress could grant residents of the District of Columbia a right to sue residents of other states. However, opponents of the constitutionality of the legislation to grant D.C. voting rights point out that seven of the nine Justices in Tidewater rejected the view that the District is a “state” for other constitutional purposes. Opponents have also pointed out that if the power of Congress to "exercise exclusive legislation" over the District is used to supersede other sections of the Constitution, then the powers granted to Congress could potentially be unlimited. On January 24, 2007, the Congressional Research Service (CRS) issued a report on this subject. According to the CRS, "it would appear likely that the Congress does not have authority to grant voting representation in the House of Representatives to the District." A secondary criticism of a legislative remedy is that any law granting representation to the District could be undone in the future. Additionally, recent legislative proposals deal with granting representation in the