The phrase "states' rights", literally referring to powers of individual state governments in the United States, was described in 2007 by David Greenberg in "Slate" as "code words" for institutionalized segregation and racism. "States' rights" was the banner under which groups like the Defenders of State Sovereignty and Individual Liberties argued in 1955 against school desegregation. In 1981, former Republican Party strategist Lee Atwater, when giving an anonymous interview discussing Nixon's Southern Strategy, speculated that terms like “states’ rights” were used for dog-whistling: