Thus, wherever woman turns in this boasted republic, from ocean to ocean, from lakes to gulf, seeking the citizen's right of self-representation, she is met by a dead wall of constitutional prohibition. It has been held in some of the States that this applies only to State and county suffrage and that the Legislature has power to grant the Municipal Franchise to women. Kansas is the only one, however, which has given such a vote. A bill for this purpose passed the Legislature of Michigan, after years of effort on the part of women, and was at once declared unconstitutional by its Supreme Court. Similar bills have been defeated in many Legislatures on the ground of unconstitutionality. It is claimed generally that they may bestow School Suffrage and this has been granted in over half the States, but frequently it is vetoed by the Governor as unconstitutional, as has been done several times in California. In New York, after four Acts of the Legislature attempting to give School Suffrage to all women, three decisions of the highest courts confined it simply to those of villages and country districts where questions are decided at "school meetings." Eminent lawyers hold that even this is "unconstitutional." (See chapter on New York.) The Legislature and courts of Wisconsin have been trying since 1885 to give complete School Suffrage to women and yet they are enabled to exercise it this year (1902) for the first time. (See chapter on Wisconsin.) Some State constitutions provide, as in Rhode Island, that no form even of School Suffrage can be conferred on women until it has been submitted as an amendment and sanctioned by a majority of the voters. The constitutions of a number of States declare that it shall not be sufficient to carry an amendment for it to receive a majority of the votes cast upon it, but it must have a majority of the largest vote cast at the election. Not one State where this in the case ever has been able to secure an amendment for any purpose whatever. Minnesota submitted this question itself to the electors in 1898 in the form of an amendment and it was carried, receiving a total of 102,641, yet the largest number of votes cast at that election was 251,250, so if its own provisions had been required it would have been lost. Nebraska is about to make an effort to get rid of such a provision, but, as this can be done only by another amendment to the constitution, the dilemma is presented of the improbability of securing a vote for it which shall be equal to the majority of the highest number cast at the general election. Since it is impossible to get such a vote even on questions to which there is no special objection, it is clearly evident that an amendment enfranchising women, to which there is a large and strong opposition, would have no chance whatever in States making the above requirement.