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2. Justice giving the Type of opinion Black incorporation preferred Argument against other approach to incorporation Cite a phrase from the opinion expressing the benefit of the justice's preferred approach.​

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Justice preferred the strong incorporation type of opinion, which means that the Bill of Rights fully applies to the states. This approach provides a more comprehensive protection of individual rights and prevents the states from violating citizens' constitutional rights. Justice argued that the other approach of selective incorporation, which applies only some rights to the states, is unreliable and unpredictable. The phrase "constitutional security" is used by Justice to express the benefit of the strong incorporation approach. It ensures that citizens' fundamental liberties are protected by the Constitution throughout the nation.

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