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Indeed, in all three states that recently ratified the E.R.A., ratification debates emphasized the persevering with need for legislation and public policy to handle remaining manifestations of gender inequality — even earlier than Dobbs. These embody pay inequity, often attributable to office disadvantages girls face because of pregnancy, motherhood and caregiving obligations, and the persistence of sexual assault and harassment. The 14th Amendment was itself a direct response to a Supreme Court choice, Dred Scott v. Sanford, which in 1857 held that Black folks could by no means be U.S. citizens. The 14th Amendment overruled that holding, conferring citizenship on all individuals born or naturalized within the United States. Congress has taken renewed interest within the E.R.A., particularly because the Supreme Court ended women’s constitutional proper to abortion in Dobbs — though it wasn’t Dobbs alone.