After the clarification of the historical record offered by the book, the Epilogue explores the implications of this history for modern disputes between the Supreme Court and Congress. Given that the history offered in these pages stops around 1910, and as such is necessarily incomplete, the Epilogue seeks to draw a somewhat limited comparison between the Voting Rights Act of 1965 – in particular, the preclearance regime of Sections 4(b) and 5 – and past congressional voting rights efforts during Reconstruction and its aftermath. Notably, the Voting Rights Act was built on the framework created by Reconstruction era Republicans, but the Act also reflects lessons learned from a nineteenth century Supreme Court hostile to broad federal power.