On March 23, 2020, in Comcast Corp. v. National Association of African-American Owned Media, the Supreme Court unanimously held that racial minorities have to allege facts suggesting “but for” causation in order to bring a claim under 42 U.S.C. § 1981 for race discrimination in contracting. This is a devastating blow to would-be civil rights litigants, particularly African Americans. Long marginalized by society due to systemic racism, many African Americans have slim to no protections under federal law and no way to enter essential sectors of public and private life, such as housing, education, healthcare, and even certain job opportunities.