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=== Guarantee Clause === The [[Guarantee Clause]] of the US Constitution requires the federal government to "guarantee to every State in this Union a Republican Form of Government." The Supreme Court has ruled that this clause does not imply any set of "judicially manageable standards which a court could utilize independently in order to identify a State's lawful government."<ref>''Baker v. Carr'', 369 U.S. 186, 223 (1962).</ref> On this ground, the Court refused to identify the legitimate [[government of Rhode Island]] during the [[Dorr Rebellion]] in ''[[Luther v. Borden]]'' (1849).<ref>48 U.S. 1 (1849)</ref><ref>Note, Political Rights as Political Questions: The Paradox of Luther v. Borden, 100 Harv.L.Rev. 1125 (1987).</ref> Since then, the Court has consistently refused to resort to the Guarantee Clause as a constitutional source for invalidating state action, such as whether it is lawful for states to adopt laws through referendums.<ref name=":0" /><ref>Pacific States Telephone & Telegraph Co. v. State of Oregon, 223 U.S. 118, 32 S. Ct. 224 (1912)</ref>
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