 which allowed Alabama essentially to disenfranchise all black people simply by using ruses like literacy tests and poll taxes. And this is an example of Holmes' radical deference and realism in its darker side. Holmes said, well, if the claim is that Alabama's perpetrating a fraud on black voters, we the court don't want to be a party to the fraud by trying to stop it and ordering the enfranchisement of one or two people. But then he said more directly,