Shortly after the adoption of the Voting Rights Act of 1965, progressive reformers recognized new threats to minority representation that went beyond minority disenfranchisement and included efforts to dilute minority representation. Progressive justices aligned with the Democratic Party helped to refashion election law to address these evolving shortcomings by reinterpreting the statute as well as the Fourteenth and Fifteenth Amendments. Conservative justices countered by proposing new, restrictive doctrinal positions. But when those positions deviated from the wishes of elected Republicans, they capitulated and instead developed a new right discouraging racial gerrymandering. The pattern of evolving doctrinal positions is best described by the deliberative partnership thesis.