Will Baude raises the question in light of Shelby County. I address this issue briefly in my APSA paper, Shelby County and the Illusion of Minimalism. My bottom line is yes, Section 2 is in danger of being struck down as an unconstitutional exercise of congressional power under Shelby County. It was in danger before, and Shelby County moderately increases that danger. Unlike section 5, section 2 has no geographic or temporal limits, and further the majority might see it as not congruent and proportional to actual constitutional violations by states in crafting their district lines and other voting rules. I plan to write more on this in the future.