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Repressive bills have proliferated in the past 5 years, but legislators do face obstacles when engaging in legislative repression. The possibility of judicial review, and the resultant rulings on the constitutionality of such bills, provides a structural impediment to development of repressive policies. Similarly, the salience of rights in the United States may provide a cultural obstacle for the passage of repressive legislation. I examine how legislators attempt to overcome these obstacles through their use of official frames to justify repressive policies in Tennessee and Kentucky. Examining these justifications can help us understand how legislators attempt to use policy to shape the legal and cultural environment in which movements operate.