In Richardson v. Ramirez (1974) 418 U.S. 24, the court reviewed the decision by the California Supreme Court that had concluded that equal protection prohibited disenfranchising "ex-felons," that is, felons who had already completed their sentence and parole. (418 U.S. at pp. 26, 31.) Specifically, Richardson addressed whether the predecessor to article II, section 4 of the California Constitution--which disenfranchised anyone convicted of "an infamous crime"--violated equal protection. And held that it did not. The petitioner in Richardson, the Mendocino County Clerk, argued that the disenfranchisement of "ex-felons" was exempted from equal protection under section 2 of the Fourteenth Amendment. (Richardson, supra, 418 U.S. at p. 37.) She reasoned that "those who framed and adopted the Fourteenth Amendment could not have intended to prohibit outright in 1 of that Amendment that which was expressly exempted from the lesser sanction of reduced representation imposed by 2 of the Amendment." (Id. at p. 43.) The Supreme Court found this "a persuasive argument unless it can be shown that the language of 2, 'except for participation in rebellion, or other crime,' was intended to have a different meaning than would appear from its face." (Ibid.) To answer that question, the court reviewed the "scant" history of section 2 to determine whether "this language was intended by Congress to means what it says." (418 U.S. at p. 43.) That history showed that "the framers of the Amendment were primarily concerned with the effect of reduced representation upon the States, rather than with the two forms of disenfranchisement which were exempted from that consequence by the language" at issue in Richardson. (Ibid.) Indeed, the history gave no indication that section 2 had any meaning other than that which appeared from its plain language. (418 U.S. at pp. 44-48.) This purpose led the court to conclude that under section 2, disenfranchisement of felons is exempted from the equal protection clause in section 1 of the Fourteenth Amendment. (418 U.S. at pp. 54-55.)