Virginia became the 38th state to ratify the Equal Rights Amendment, fulfilling the requirement that three-quarters of the states must approve it in order to add it to the U.S. Constitution. However, there is still a long fight in the courts or in the U.S. legislature before the ERA is added to the Constitution. The Equal Rights Amendment was written in 1923 by members of the National Woman’s Party and passed by Congress in 1972. It stated that equality of rights under the law shall not be denied or abridged by the United States or any State on account of sex. It took effect two years after the date of ratification. Alice Paul, the founder of the National Woman’s Party, proposed the Equal Rights Amendment in 1913. She studied at colleges and universities in the U.S. and Britain, and pushed American suffragists to use confrontational techniques. In 1917, she was sentenced to seven months in prison for picketing the White House. After women won the right to vote in 1920, the National Woman’s Party turned its attention to the next steps. Jessica Neuwirth, a women’s rights lawyer, and Martha Griffiths, a Michigan Congresswoman, worked to have sex discrimination added to Title VII of the 1964 Civil Rights Act. The Equal Rights Amendment of 1972 failed due to a seven-year deadline for ratification, which slowed to a trickle. Griffiths reintroduced the amendment the following year and it passed the House and Senate in 1972.