\u201cThe day I stop learning is the day I die,\u201d exclaimed a Maine\u00a0resident registering to vote. The 2020 presidential election was this\u00a0anonymous voter\u2019s first time filling out the age-old symbol of\u00a0democracy\u2014a ballot\u2014and he did it from behind the bars of a prison\u00a0cell. Maine is one of only four U.S. jurisdictions to allow currently\u00a0incarcerated citizens to vote, but this Essay will make the case for\u00a0expanding that right to vote to all incarcerated individuals in the United\u00a0States. Part I will survey a brief legal history of felon voting rights, from\u00a0the state codification of disenfranchisement for all felons to the modern\u00a0era of restoring the right to vote for those who have completed their\u00a0prison sentence. Part II will explore the modern arguments for\u00a0expanding voting rights to currently incarcerated individuals and\u00a0examine two states that already have this practice in place, Maine and\u00a0Vermont. Part III will describe the horizontal scaling (i.e. state action)\u00a0efforts of this policy innovation, but, ultimately argue that state\u00a0governments are an ineffective path to universal suffrage. Finally, Part\u00a0IV will argue that because horizontal scaling is limited and unstable,\u00a0vertical scaling (i.e. federal action) is necessary to restore prisoner\u2019s\u00a0voting rights, thus building a more democratic and just society, even for\u00a0those serving a prison sentence.<\/p>\n