City of Memphis, Tennessee et al. v. Tre Hargett et al. - CONCUR

In 2011, the Tennessee General Assembly amended Tennessee’s voting procedures to provide for the use of photographic identification in elections. The General Assembly amended these procedures in 20122 and again in 2013.3 I concur with the Court’s decision to uphold the constitutionality of these procedures as they stood in 2012. I write separately, however, to address the threshold matter of the standard of review that should be used to address the constitutionality of these amendments.