The petition for a writ of certiorari should be granted. The Court’s language in Rice v. Cayetano makes it clear that there are three categories of protected citizens within the Fifteenth Amendment: race, color, and previous condition of servitude. And Rice only deals with race. Thus, the district court did not consider the other two categories of protected citizens in its ruling. And the Ninth Circuit affirmed the district court ruling. The lower courts failed to incorporate the three conditions (race, color, and previous condition of servitude), covered under the Fifteenth Amendment as provided in Rice in their decision.
https://prisonertheory.com/slavery