Legislation is the product of more than just a vote in two chambers of Congress. The court’s conservative majority often engages in some sleight of hand when it comes to Congress and its powers. While the court claimed that Congress “may draft another formula based on current conditions,” the destruction of the rest of the VRA casts serious doubts about that promise. It is not surprising that conservatives fear a powerful Congress, for it is a powerful Congress that has often achieved the most far-reaching changes to American society. Progressives in Congress at the turn of the twentieth century enacted the first federal labor, antitrust, and consumer protection laws.