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I begin with the centerpiece of the conflict about the Violence Against Women Act of 1994 (VAWA)—the civil rights remedy of VAWA.2 Its words were both carefully thought out and negotiated, and hence the exact terms are important to know. Key to what Congress entitled the “Civil Rights” remedy of VAWA is its provision: “All persons within the United States shall have the right to be free from crimes of violence motivated by gender . . . .” In addition, Congress specified a right to obtain supplemental remedies in federal court atop what other provisions might be available under state law—provided to “all persons” subjected to what VAWA recognized as violations of liberty, autonomy, and equality.
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