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Congress, the majority said, first responded to this inequality by passing Title VII of the Civil Rights Act of 1964. Title VII's abrogation of state sovereign immunity was upheld in Fitzpatrick v. Bitzer, "[b]ut," the Court said, "state gender discrimination did not cease."[14] The Court noted that "the persistence of such unconstitutional discrimination by the States justifie[d]" the passage of the FMLA, which was designed to prevent further discrimination.[14].

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