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In page Human rights in the United States:

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In the 1970s, the Burger Court made a series of rulings clarifying that discrimination against women in the status of being Persons violated the Constitution and acknowledged that previous court rulings to the contrary had been sui generis and an abuse of power. The most often cited of these is Reed v. Reed, which held that any discrimination against either sex in the rights associated with Person status must meet a strict scrutiny standard.[citation needed]