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A federal appeals panel has made enforcing the Voting Rights Act harder in 7 states
A demonstrator carrying a sign that says “VOTING RIGHTS NOW” walks across the Frederick Douglass Memorial Bridge in 2022 in Washington, D.C.
Samuel Corum/Getty Images
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A panel of the 8th U.S. Circuit Court of Appeals has struck down one of the key remaining ways of enforcing the federal Voting Rights Act in seven mainly Midwestern states.
For decades, private individuals and groups have brought the majority of lawsuits for enforcing the landmark law’s Section 2 protections against racial discrimination in the election process.
But in a 2-1 ruling released Wednesday, the three-judge panel found that Section 2 cannot be enforced by lawsuits from private parties under a separate federal statute known as Section 1983.
That statute gives individuals the right to sue state and local government officials for violating their civil rights. Section 1983 stems from the Ku Klux Klan Act that Congress passed after the Civil War to protect Black people in the South from white supremacist violence, and voting rights advocates have considered it an antidote to a controversial 2023 decision by a different federal appeals panel that made it harder to enforce Section 2 in the 8th Circuit.
That earlier panel found that Section 2 is not privately enforceable because the Voting Rights Act does not explicitly name private individuals and groups. Only the head of the Justice Department can bring these types of lawsuits, that panel concluded.

The majority of the panel that released Wednesday’s opinion came to the same conclusion.
“Because [the Voting Rights Act’s Section 2] does not unambiguously confer an individual right, the plaintiffs do not have a cause of action under [Section 1983 of Title 42 of the U.S. Code] to enforce [Section 2] of the Act,” wrote Circuit Judge Raymond Gruender, who was nominated by former President George W. Bush and joined in the opinion by Circuit Judge Jonathan Kobes, a nominee of President Trump.
In a dissenting opinion, however, Chief Circuit Judge Steven Colloton, also a Bush nominee, pointed out the long history of private individuals and groups suing to enforce Section 2’s legal protections against any inequalities in the opportunities voters of colors have to elect preferred candidates in districts where voting is racially polarized.
“Since 1982, private plaintiffs have brought more than 400 actions based on [Section 2] that have resulted in judicial decisions. The majority concludes that all of those cases should have been dismissed because [Section 2] of the Voting Rights Act does not confer a voting right,” Colloton wrote.
Under the current Trump administration, the Justice Department has stepped away from Section 2 cases that had begun during the Biden administration.
The 8th Circuit includes Arkansas, Iowa, Minnesota, Missouri, Nebraska, North Dakota and South Dakota. The latest ruling comes out of a North Dakota redistricting lawsuit by the Turtle Mountain Band of Chippewa Indians and the Spirit Lake Tribe. Citing Section 1983 as a basis for bringing the case as private groups, the tribal nations challenged a map of state legislative voting districts, which was approved by North Dakota’s Republican-controlled legislature after the 2020 census.
In a part of the state where voting is racially polarized, the tribal nations argued, the redistricting lines drawn by the state lawmakers reduce the opportunity for Native American voters to elect candidates of their choice.
“For the first time in over 30 years, there are zero Native Americans serving in the North Dakota state Senate today because of the way the 2020 redistricting lines were configured,” Mark Gaber, an attorney with the Campaign Legal Center, which is representing the tribal nations, said during a court hearing in October 2024.
A lower court struck down the redistricting plan for violating Section 2 by diluting the collective power of Native American voters in northeastern North Dakota.
But the state’s Republican secretary of state, Michael Howe, appealed the lower court’s ruling to the 8th Circuit, arguing that, contrary to decades of precedent, Section 1983 does not allow private individuals and groups to bring this kind of lawsuit.
Since 2021, Republican officials in Arkansas and Louisiana have made similar novel arguments in redistricting lawsuits after Justice Neil Gorsuch, Trump’s first Supreme Court appointee, issued a single-paragraph opinion that said lower courts have considered whether private individuals can sue an “open question.” For this North Dakota lawsuit, 14 GOP state attorneys general signed on to a friend-of-the-court brief arguing that private parties don’t have a right to sue with Section 2 claims.
In a separate Arkansas-based case before the 8th Circuit, GOP state officials have also questioned whether there is a private right of action under another part of the Voting Rights Acts — Section 208, which states that voters who need assistance to vote because of a disability or inability to read or write can generally receive help from a person of their choice.
Many legal experts consider this questioning of a private right of action as the prelude to the next potential showdown over the Voting Rights Act at the Supreme Court, where multiple rulings by the court’s conservative majority have eroded the law’s protections over the past decade.
Edited by Benjamin Swasey
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Trump’s BBC lawsuit: A botched report, BritBox, and porn
Journalists report outside BBC Broadcasting House in London. In a new lawsuit, President Trump is seeking $10 billion from the BBC for defamation.
Kirsty Wigglesworth/AP/AP
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Kirsty Wigglesworth/AP/AP
Not content with an apology and the resignation of two top BBC executives, President Trump filed a $10 billion defamation lawsuit Monday against the BBC in his continued strategy to take the press to court.
Beyond the legal attack on yet another media outlet, the litigation represents an audacious move against a national institution of a trusted ally. It hinges on an edit presented in a documentary of the president’s words on a fateful day. Oddly enough, it also hinges on the appeal of a niche streaming service to people in Florida, and the use of a technological innovation embraced by porn devotees.
A sloppy edit
At the heart of Trump’s case stands an episode of the BBC television documentary program Panorama that compresses comments Trump made to his supporters on Jan. 6, 2021, before they laid siege to the U.S. Capitol.
The episode seamlessly links Trump’s call for people to walk up to the Capitol with his exhortation nearly 55 minutes later: “And we fight, we fight like hell, and if you don’t fight like hell you don’t have a country anymore.”
Trump’s attorneys argue that the presentation gives viewers the impression that the president incited the violence that followed. They said his remarks had been doctored, not edited, and noted the omission of his statement that protesters would be “marching over to the Capitol building to peacefully and patriotically make your voices heard.”
As NPR and other news organizations have documented, many defendants in the Jan. 6 attack on Congress said they believed they had been explicitly urged by Trump to block the certification of President-elect Joe Biden’s victory.
Trump’s lawsuit calls the documentary “a false, defamatory, deceptive, disparaging, inflammatory, and malicious depiction of President Trump.”
The lawsuit alleges that the depiction was “fabricated” and aired “in a brazen attempt to interfere in and influence the Election to President Trump’s detriment.”
While the BBC has not filed a formal response to the lawsuit, the public broadcaster has reiterated that it will defend itself in court.
A Nov. 13 letter to Trump’s legal team on behalf of the BBC from Charles Tobin, a leading U.S. First Amendment attorney, argued that the broadcaster has demonstrated contrition by apologizing, withdrawing the broadcast, and accepting the executives’ resignations.
Tobin also noted, on behalf of the BBC, that Trump had already been indicted by a grand jury on four criminal counts stemming from his efforts to overturn the 2020 election, including his conduct on Jan. 6, 2021, on the Capitol grounds.
The appeal of BritBox
For all the current consternation about the documentary, it didn’t get much attention at the time. The BBC aired the documentary twice on the eve of the 2024 elections — but never broadcast it directly in Florida.
That matters because the lawsuit was filed in Florida, where Trump alleges that the program was intended to discourage voters from voting for him.
Yet Tobin notes, Trump won Florida in 2024 by a “commanding 13-point margin, improving over his 2020 and 2016 performances in the state.”
Trump failed to make the case that Floridians were influenced by the documentary, Tobin wrote. He said the BBC did not broadcast the program in Florida through U.S. channels. (The BBC has distribution deals with PBS and NPR and their member stations for television and radio programs, respectively, but not to air Panorama.)
It was “geographically restricted” to U.K. viewers, Tobin wrote.
Hence the argument in Trump’s lawsuit that American viewers have other ways to watch it. The first is BritBox, a BBC streaming service that draws more on British mysteries set at seaside locales than BBC coverage of American politics.
Back in March, then-BBC Director General Tim Davie testified before the House of Commons that BritBox had more than 4 million subscribers in the U.S. (The BBC did not break down how many subscribers it has in Florida or how often Panorama documentaries are viewed by subscribers in the U.S. or the state, in response to questions posed by NPR for this story.)
“The Panorama Documentary was available to BritBox subscribers in Florida and was in fact viewed by these subscribers through BritBox and other means provided by the BBC,” Trump’s lawsuit states.
NPR searched for Panorama documentaries on the BritBox streaming service through the Amazon Prime platform, one of its primary distributors. The sole available episode dates from 2000. Trump does not mention podcasts. Panorama is streamed on BBC Sounds. Its episodes do not appear to be available in the U.S. on such mainstream podcast distributors in the U.S. such as Apple Podcasts, Spotify or Pocket Casts, according to a review by NPR.
Software that enables anonymous browsing – of porn
Another way Trump’s lawsuit suggests people in the U.S. could watch that particular episode of Panorama, if they were so inclined, is through a Virtual Private Network, or VPN.
Trump’s suit says millions of Florida citizens use VPNs to view content from foreign streamers that would otherwise be restricted. And the BBC iPlayer is among the most popular streaming services accessed by viewers using a VPN, Trump’s lawsuit asserts.
In response to questions from NPR, the BBC declined to break down figures for how many people in the U.S. access the BBC iPlayer through VPNs.
Demand for such software did shoot up in 2024 and early 2025. Yet, according to analysts — and even to materials cited by the president’s team in his own case — the reason appears to have less to do with foreign television shows and more to do with online pornography.
Under a new law, Florida began requiring age verification checks for visitors to pornographic websites, notes Paul Bischoff, editor of Comparitech, a site that reviews personal cybersecurity software.
“People use VPNs to get around those age verification and site blocks,” Bischoff says. “The reason is obvious.”
An article in the Tampa Free Press cited by Trump’s lawsuit to help propel the idea of a sharp growth of interest in the BBC actually undercuts the idea in its very first sentence – by focusing on that law.
“Demand for Virtual Private Networks (VPNs) has skyrocketed in Florida following the implementation of a new law requiring age verification for access to adult websites,” the first paragraph states. “This dramatic increase reflects a widespread effort by Floridians to bypass the restrictions and access adult content.”
Several legal observers anticipate possible settlement
Several First Amendment attorneys tell NPR they believe Trump’s lawsuit will result in a settlement of some kind, in part because there’s new precedent. In the past year, the parent companies of ABC News and CBS News have each paid $16 million to settle cases filed by Trump that many legal observers considered specious.
“The facts benefit Trump and defendants may be concerned about reputational harm,” says Carl Tobias, a professor of law at the University of Richmond who specializes in free speech issues. “The BBC also has admitted it could have done better and essentially apologized.”
Some of Trump’s previous lawsuits against the media have failed. He is currently also suing the New York Times, the Wall Street Journal, the Des Moines Register and its former pollster, and the board of the Pulitzer Prize.
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Video: Prosecutors Charge Nick Reiner With Murdering His Parents
new video loaded: Prosecutors Charge Nick Reiner With Murdering His Parents
transcript
transcript
Prosecutors Charge Nick Reiner With Murdering His Parents
Los Angeles prosecutors charged Nick Reiner with two counts of first-degree murder in the deaths of his parents, the director Rob Reiner and Michele Singer Reiner.
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Our office will be filing charges against Nick Reiner, who is accused of killing his parents, actor-director Rob Reiner and photographer-producer Michele Singer Reiner. These charges will be two counts of first-degree murder, with a special circumstance of multiple murders. He also faces a special allegation that he personally used a dangerous and deadly weapon, that being a knife. These charges carry a maximum sentence of life in prison without the possibility parole or the death penalty. No decision at this point has been made with respect to the death penalty.
By Shawn Paik
December 16, 2025
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Nick Reiner will be charged with first degree murder in his parents’ killing
Michele Singer Reiner, Rob Reiner and their son Nick in 2013.
Michael Buckner/Getty Images for Teen Vogue
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Michael Buckner/Getty Images for Teen Vogue
Nick Reiner, the 32-year-old son of filmmaker Rob Reiner and photographer Michele Singer Reiner, is being charged with two counts of first degree murder. Los Angeles County District Attorney Nathan J. Hochman said at a press conference Tuesday that the charges include a “special circumstance” of multiple murders and a “special allegation” that Reiner used a dangerous and deadly weapon — a knife.

The charges carry a maximum sentence of life in prison without the possibility of parole.
“No decision at this point has been made with respect to the death penalty,” Hochman added.
Hochman called Rob Reiner an “iconic force in our entertainment industry” and his wife Michele Singer Reiner an “equally iconic photographer and producer.” The police became aware of their deaths on Sunday after a call from the fire department. Los Angeles Police Chief Jim McDonnell said the cause and time of the deaths aren’t available at this time as they await updates from the coroner’s office.
Alan Hamilton, deputy chief of the Los Angeles Police Department, said that Nick Reiner was arrested in public on Sunday, in the Exposition Park area of Los Angeles, near the University of Southern California campus. In response to questions, McDonnell said he was unable to say whether or not Nick Reiner was under the influence of drugs at the time of his arrest. Reiner had been open about his struggles with addiction in the past.


When asked whether there was evidence of mental illness in Nick Reiner’s background, Hochman said “any evidence, if there is any” would be presented in court. Hochman wouldn’t answer a question about whether Reiner admitted to the crimes, saying that is the type of evidence that would come out in court.
Hochman emphasized that “charges are not evidence” and that his office would be presenting evidence to jurors in a court of law. He asked people to rely on trusted sources and not hearsay about the case.
He said that, as in any case, his office would be taking “the thoughts and desires of the family into consideration.”
Prosecutors are filing charges Tuesday afternoon. Reiner is going through medical clearance – a normal process, according to officials – and will be brought to court for arraignment, where he will enter a plea. Reiner is currently being held without bail.


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