In 2018, critics accused the state of intentionally disenfranchising non-white voters. Disenfranchising provisions worked against poor whites as well as blacks for decades. They did not repeal the Italian Penal Code, effectively disenfranchising Eritrea in any criminal proceedings. They kept the seat through much of the 1960s, largely because of disenfranchising blacks. In the early 20th century, Virginia had passed a new constitution disenfranchising most blacks. Mississippi led the South in developing a disenfranchising constitution, passing it in 1890. In "Giles v. Teasley" (1904), the U.S. Supreme Court upheld Alabama's disenfranchising constitution.