The U.S. Court of Appeals for the Eighth Circuit recently held, as a matter of first impression, that private parties may not sue to enforce Section 2 of the Voting Rights Act. Instead, lawsuits to enforce Section 2 can only be brought by the Attorney General of the United States. Judge David R. Stras wrote the opinion, with Judge Raymond W. Gruender joining. Chief Judge Lavenski R. Smith dissented.