Michelle Yeoh is one of the greatest actors of our generation, as evidenced by Yeoh's historic Oscar win for Everything Everywhere All at Once. Audiences now associate her with that film and her role as Captain Philippa Georgiou in Star Trek: Discovery. But there's one project for which Yeoh has never gotten enough credit: her 2015 appearance on Cinemax's Strike Back. As the cunning, brutal yet also dignified Mei Foster, Yeoh drove the fourth season of the series with a captivating performance.
While Strike Back received plenty of attention for its jaw-dropping action, it was never recognized for the incredible acting that was consistent throughout the series. From the original Sky series to the seven seasons which aired on Cinemax, the show attracted wonderful talent and Yeoh was among the best. Her character Mei Foster/Li-Na challenged Section 20 throughout Strike Back Season 4 and was responsible for one of the most devastating yet beautiful scenes in series history. She deserved an Emmy to go along with that Oscar -- but hopefully viewers will go back and watch her most underrated role.
As befits any great thriller, Strike Back featured plenty of betrayals. But Mei Foster's turn from ambassador's wife to his murderer was one of the more interesting ones because of her fully realized character arc. It wasn't solely that Mei/Li-Na was a deep-cover operative from North Korea's villainous Office 39, although the series took advantage of Yeoh's action movie background. Audiences were privy to Li-Na's thoughts and understood her motivations. She was fighting not for personal gain but for her country, which she saw as unjustly abused by the West during the Cold War. Even in the more typical villain scenes, plotting her moves, Yeoh gave Li-Na conviction, grace and a quiet pain. She was also human -- nearly being executed by her father before she went rogue. Michelle Yeoh's ability to carry the character from charming to frightening to vulnerable made all that possible.
Li-Na's relationship with Kwon was given the kind of depth and emotion not normally afforded to villains -- because Yeoh and Will Yun Lee had a genuine rapport. In the way that The Americans humanized Russian spies, the Li-Na and Kwon story did the same, in that viewers felt the characters' mutual respect and care for one another down to the very end. There was a want for them to survive, even though they and the audience knew there was no way out. Even against the immovable object that was Philip Winchester's brilliant Michael Stonebridge, Li-Na was intimidating and human. That was a large part of why Strike Back Season 4 worked: all of the characters had a journey to take and something worth dying for.
Michelle Yeoh was front and center for one of Strike Back's most heartwrenching scenes: the murder of Sergeant Julia Richmond. Michelle Lukes' Richmond was a fan-favorite for many reasons -- she was one of the last original Section 20 members standing, and Lukes was an integral part of the series with her wit and warmth. Her portrayal of Richmond was everything a strong female character should be, which made it crushing when Li-Na killed her. However, writer James Dormer crafted a perfect sequence leading up to that moment as Richmond matched wits with Li-Na at gunpoint in the back of a car. The scene was simply two wonderful actors engaging each other in conversation, with the ultimate stakes.
In a series defined by its gunfights and narrow escapes, it was painfully beautiful to have a moment that was quiet and from which the viewer knew there would be no escape. Lukes' emotion in the scene was devastating, particularly her look after Li-Na asked Richmond if she had anyone to live for; the audience could tell Richmond knew she was going to die. This was immediately followed by Li-Na comforting Richmond by placing a hand on her arm, showing rare compassion for a villain. That moment succeeded because the respect between Yeoh and Lukes was clear in the scene. Even though the characters were at odds, the actors worked together to tell an emotional story that affected both characters. It was so much more than a death scene. For that reason, it's one of Strike Back's best moments -- and one of the best character deaths in any TV series.
Hopefully Michelle Yeoh's Oscar win means her Star Trek Section 31 spinoff is picked up to series, because she deserves a show of her own. But before that happened, her portrayal of a more modern spy deserved far more acclaim than it ever got. She stepped into one of the most challenging and well-acted TV shows in recent memory, and she took it to another level. She shaped an antagonist who actually had a positive effect on the viewer and who enabled great moments for the heroes. Strike Back is one of her best performances in a legendary career.
Voter intimidation has been a recurring problem throughout the history of the United States.[18] Until the early 1960s, blacks routinely faced physical violence and economic reprisal for even attempting to register to vote.[19] That type of overtly racist intimidation dramatically declined after the federal government enacted new civil rights laws and began enforcing them aggressively. Today, voter intimidation is a significantly less pernicious influence on American elections than it was during the civil rights era.
Such conduct is emblematic of modern voter intimidation. Today, voters are rarely overtly threatened with physical or economic harm as they were during the civil rights era; instead, voters are deterred from voting through subtler tactics, such as aggressive poll-watching, anonymous threats of harm, frivolous and excessive voter registration challenges, and coercion by employers.[24] This shift towards subtler methods of intimidation mirrors what has been seen in the employment context, where instances of overt discrimination have declined with the rise of tougher anti-discrimination laws.[25]
The usual response to these aggressive tactics has been to file complaints with election officials or law enforcement agencies, but this often results in minimal legal action.[28] Section 11(b), however, prohibits this kind of disenfranchisement and empowers victims to strike back against intimidation, threats, and coercion engineered to suppress their votes.
That voting rights litigators have not more aggressively sought to test the boundaries of section 11(b) is likely due to a combination of factors. An individual voter does not have much incentive to file a voter intimidation lawsuit on her own behalf, particularly if she was ultimately able to cast her ballot. For organizational plaintiffs, like civil rights groups or political organizations, simple cost-benefit analysis may not always justify a voter intimidation suit. After all, the number of individuals affected by voter intimidation is low compared to those affected by higher-profile issues like voter identification and the availability of early voting.[31] And such suits may be even less attractive to would-be challengers given the untested nature of the claims discussed in this article. So, while voter intimidation can make news when it happens, it is rare for litigants to actually challenge it in court. With that in mind, the authors hope that this article will help lower the cost of bringing a voter intimidation suit by explaining how the law works and laying out a viable path for bringing claims.
Part V concludes by offering practical advice to litigators in advancing voter intimidation claims, including suggestions on structuring legal arguments, selecting parties, and formulating relief.[37]
The right to vote has changed significantly over the course of American history. Who possesses this right, how they may exercise it, and for what offices they may vote has changed from state to state and era to era. While the arc of American history has bent towards an expansion of the franchise, this expansion has not always come easily, often meeting fierce resistance from those in and out of government. Along the way, at several key moments, Congress played an important part in expanding the franchise. Congress passed the KKK Act during Reconstruction and the Voting Rights Act during the civil rights era.[38] These were defining national episodes. And these statutes were correspondingly ambitious in scope, seeking in a real way to define the terms of national citizenship. In doing so, these laws grappled directly with the long history of exclusion in American politics.
Congress intended the Ku Klux Klan Act and the Voting Rights Act to combat these deeply rooted historical and cultural forces. These laws intervene on a granular level, to the level of individual citizens, for the purpose of securing the rights of national citizenship. They make it a federal crime to deprive individuals of the right to vote.[50] They create private rights of action in federal courts.[51] They set federal standards for the administration of elections.[52] In essence, they interject the full force of the federal government between eligible voters and those individuals and groups who seek to keep them from voting.
As the arguments described above might suggest, the franchise was extremely limited at the time of the founding. Between the founding and the Civil War, states gradually adopted reforms to increase the size and scope of the electorate.[53] However, women and racial minorities continued to be denied the franchise.[54] Thus, the attempt to enfranchise African American men during Reconstruction represented a rapid and dramatic expansion of voting rights.
The bill created a national Civil Rights Commission, elevated the Civil Rights section into a full-fledged division of the Justice Department, and authorized the attorney general to seek injunctions and file civil suits in voting rights cases. The operative heart of the measure was a strengthening of the machinery that the Justice Department and federal judges could utilize to respond to violations of existing voting rights laws, including the Fifteenth Amendment.[96]
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