Because state courts rarely prosecuted acts of violence against the freed slaves of the South, the Enforcement Act of 1870Enforcement Act of 1870 made it a federal crime to engage in a conspiracy to deprive a citizen of constitutional rights. In Colfax, Louisiana, an armed group of white rioters killed about one hundred blacks gathered for a political meeting. Federal prosecutors used the Enforcement Act to prosecute and convict William Cruikshank and two others for participating in the Colfax massacre.[case]Cruikshank, United States v.[Cruikshank, United States v.]Civil rights and liberties;Cruikshank, United States v.[Cruikshank, United States v.]States’ rights;Cruikshank, United States v.[Cruikshank, United States v.]

The Supreme Court unanimously held that the indictments were invalid. In a complicated ruling, Chief Justice Morrison R. WaiteWaite, Morrison R.;Cruikshank, United States v.[Cruikshank, United States v.] concentrated on the difference between the rights of state and national citizenship. Any assaults on the rights of state citizenship, which included participation in state politics, were not enforceable in federal courts. In addition, the due process and equal protection clauses of the Fourteenth Amendment authorized federal legislation relating only to actions by state officials, not to acts of private persons. Finally, in charging interference with a Fifteenth Amendment right to vote, the indictments failed to specify that the defendants had been motivated by the race of the victims.

The decision in United States v. Cruikshank left protection for most African American rights with the southern states, where few people sympathized with their cause. The decision reflected the national mood, which had become tired of federal intervention in southern politics.

Fourteenth Amendment

Race and discrimination

Reconstruction

Slaughterhouse Cases

State action

States’ rights and state sovereignty