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1855
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Lecompton Constitution (Kansas)
The Lecompton Constitution was the second of four proposed constitutions for the state of Kansas The document was boycotted by anti-slavery forces and written by pro-slavery forces. It was roundly seen as a fraudulent document that was not democratically decided. Then President, James Buchanan, a supporter of slaveowner rights, decided that he would attempt to honor the constitution by saying that the the anti-slavery contingent excercised their democratic right by refusing to participate. Kansas voters rejected the Lecompton Constitution by a vote of the constitution altogether in the referendum, overwhelmingly rejected the Lecompton proposal by a ratio of almost 100 to 1.
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Bleeding Kansas
Bleeding Kansas, Bloody Kansas or the Border War, was a series of violent events, involving anti-slavery Free-Staters and pro-slavery elements that took place in the Kansas Territory between 1854 and 1858. At the heart of the conflict was the question of whether Kansas would enter the Union as a free state or slave state. the divide lead to a war between Northerners and Southerners who streamed over the border to vote, fight and debate the issue of slavery. Hundreds were mobilized and armed. 56 were killed including several pro-slavery/slave holding residents murdered by at night, in cold blood, with broad swords by John Brown, his sons and followers.
1856
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Charles Sumner is Attacked
During the "Bleeding Kansas" crisis, Sumner denounced the Kansas-Nebraska Act. In his "Crime against Kansas" speech he verbally attached Senators Stephen A. Douglas and Andrew Butler in a 2 hour speech that made direct accusations of master/slave miscegenation. Abolitionists routinely accused slaveholders of maintaining slavery so that they could engage in forcible sexual relations with their slaves." Sumner also Butler's manner of speech and physical mannerisms, which were impaired by a stroke. Representative Preston Brooks, Butler's nephew, beat Sumner savagely with a cane until his cane broke and Sumner was unresponsive. Those who attempted to come to Sumner's aid were kept at bay by Representative Keitt who brandished a pistol. Keitt was censured for his actions and Brooks was fined $300. and Sumner was not to return to the chamber for more than two years and was seen as a martyr. The violence over slavery between north and south was a sign of things to come.
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The Dred Scott Decision
The case of Scott (who sued for his freedom) and his master, Sandford (Scott v. Sandford) decided three important questions. Could a slave/former slave sue in the court of law. The Court held that Scott, as a slave was not a "citizen of a state" and therefore was unable to bring suit in federal court. On the second point, the court also found that although Scott resided in a free state for 4 years, he was still a slave, based upon the constitutional right to life, liberty and property. This verdict essentially made every state a slave state, seeing as slaveowners now had the constitutional right to bring their "property" into any other state. The final decision by the court was that the United States government, despite the Missouri Compromise and the Kansas/Nebraska Act, did not have the right to decide if any new territories would be slave or free. The Missouri Compromise was ruled in effect, unconstituational. The Dred Scott decision is seen as one of the worst and most costly decision in the history of jurisprudence.
1857
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Tariff of 1857
The Tariff of 1857 was a major tax reduction in the United States, creating a mid-century low point for tariffs to around 17% on average. The bill was offered in response to a federal budget surplus in the mid 1850s. Supporters of the bill came mostly from Southern and agricultural states, which tended to be export dependent and tended to support the "free trade" position. They were also joined by a handful of New England wool manufacturers. When the Panic of 1857 struck later that year, protectionists, led by economist Henry C. Carey, blamed the downturn on the new Tariff schedule. Though economists today reject this explanation.
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Panic of 1857 and sectional realignments
The Panic of 1857 was a financial panic in the United States caused by the declining international economy and over-expansion of the domestic economy. The financial crisis was the world's first world-wide economic crisis. In Britain, the Palmerston government circumvented the requirements of the Peel Banking Act of 1844 which required gold and silver reserves to back up the amount of money in circulation. This circumvention set off the Panic in Britain. Beginning in September 1857, the financial downturn did not last long; however, a proper recovery was not seen until the American Civil War.Contents. SECTIONAL REALIGNMENTS: The north and south blamed the panic of 1857 on the effect of one another's influence on policy. The economic difficulties leading up to the panic had the effect of strengthening the Republican Party and heightened sectional tensions. Before the panic, strong economic growth was being achieved under relatively low tariffs. Republicans urged western farmers and northern manufacturers to blame the depression on the domination of the low-tariff economic policies of southern-controlled Democratic administrations. However the depression revived suspicion of Northeastern banking interests in both the South and the West.
1858
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Oberlin-Wellington Rescue
The Oberlin-Wellington Rescue of 1858 in Lorain County, Ohio was a key event in the history of the abolitionist movement in the United States shortly before the American Civil War. John Price, an escaped slave, was arrested in Oberlin, Ohio under the Fugitive Slave Law, and taken to Wellington by the US Marshal. Rescuers took him by force from the marshals and back to Oberlin, then to freedom in Canada. Thirty-seven of the rescuers were at first indicted, but as a result of state and federal negotiations, only two were tried in federal court. The case received national attention, and defendants argued eloquently against the law. When rescue allies went to the 1859 Ohio Republican convention, they added a repeal of the Fugitive Slave Law of 1850 to the party platform. The rescue and continued activism of its participants kept the issue of slavery as part of the national discussion.
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Lincoln Douglas Debates
The Lincoln Douglas Debates of 1858 were a series of seven debates between Abraham Lincoln,and the incumbent Stephen DouglasAt the time, U.S. senators were elected by state legislatures; thus Lincoln and Douglas were trying for their respective parties to win control of the Illinois legislature. The debates previewed the issues that Lincoln would face in the aftermath of his victory in the 1860 presidential election. The main issue discussed in all seven debates was slavery. Lincoln and Douglas decided to hold one debate in each of the nine congressional districts in Illinois. After losing the election for Senator in Illinois, Lincoln edited the texts of all the debates and had them published in a book. Coverage of the original debates led to Lincoln's nomination for President of the United States by the 1860 Republican National Convention in Chicago. The format for each debate was: one candidate spoke for 60 minutes, then the other for 90 minutes, and then the first for a final 30.
1859
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Last Slave Ship Enters America
THE WANDERER and THE CLOTILDE. THE CLOTILDE arrived in Mobile Bay carrying a cargo of110-160 enslaved Africans. West African tribes were fighting, and the King of Dahomey was willing to trade Africans for US$50 each. Foster arrived in Whydah on May 15, 1859, bought Africans from several different tribes, and headed back to Mobile. When the Clotilde arrived, Federal authorities had been alerted to the illegal scheme. The African slaves were distributed to those having a financial interest in the Clotilde venture. THE WANDERER is the last documented ship to bring a cargo of slaves from Africa to the United States (on November 28, 1858). Stories of subsequent mass landings of slaves have been told, but are in dispute When the Wanderer reached Jekyll Island, Georgia from Africa, approximately 409 of the enslaved Africans had survived. The federal government prosecuted the owner and crew, but failed to win a conviction.
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John Brown's War
John Brown's raid on Harpers Ferry, also known as John Brown's raid or The raid on Harpers Ferry was an attempt by white abolitionist John Brown to start an armed slave revolt by seizing a United States Arsenal at Harpers Ferry in Virginia in 1859. Brown's raid was defeated by a detachment of U.S. Marines led by Col. Robert E. Lee. John Brown had originally asked Harriet Tubman and Frederick Douglass, both of whom he had met in his formative years as an abolitionist in Springfield. Just prior to the raid, Douglass housed Brown in his home for over a month. After the raid, Douglass slipped off to England to avoid being tried as a co-conspirator.
1860
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The Seccession Crisis
almost immediately following the election of Abraham Lincoln, southern states began to secede from the Union. Eleven of the fifteen southern states where slavery was legal declared their secession from the United States and joined together as the Confederate States of America. The remaining 4 souther border states (Delaware, Kentucky, Maryland, and Missouri), never succeeded from the Union. This is the primary reason why the Emancipation Proclamation did not apply to these states.
1861
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Ft. Sumpter is fired upon starting The Civil War
Named after General Thomas Sumter, Revolutionary War hero, Fort Sumter was built following the War of 1812, as one of a series of fortifications on the southern U.S. coast. The fort was a five-sided brick structure with walls five feet thick, standing 50 feet over the low tide mark. It was designed to house 650 men and 135 guns.The official start of the Civil war is recorded as January 9, 1861 when shots were fired to prevent the Union steamer, Star of the West from supplying the fort.
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The Corwin Constitutional Amendment
The Corwin Amendment is a proposed amendment to the United States Constitution passed on March 2, 1861. If ratified by the states, it would forbid subsequent attempts to amend the Constitution to empower the Congress to "abolish or interfere" with the "domestic institutions" of the states, including "persons held to labor or service" (a reference to slavery). Ohio Republican Representative Thomas Corwin offered the amendment in an attempt to forestall the secession of Southern states. Southern states by this point were committed to forming their own union, so they ignored the amendment. This proposed amendment is still pending before the state legislatures for ratification, because it was submitted without a deadline.
1862
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Emancipation Proclamation
The Emancipation Proclamation was issued by President Abraham Lincoln on January 1, 1863. It proclaimed the freedom of 3.1 million of the nation's 4 million slaves. The Proclamation did not compensate the owners; it did not make the ex-slaves, called Freedmen, citizens. The Proclamation did not cover the nearly 500,000 slaves in the slave-holding border states of Missouri, Kentucky, Maryland or Delaware. Tennessee was not named and was exempted. Virginia was named, but exemptions were specified for the 48 counties that were in the process of forming the new state of West Virginia. Also specifically exempted were New Orleans and 13 named parishes of Louisiana. These exemptions left 300,000 slaves un-emancipated. On the positive side, the Proclamation provided the legal framework for the emancipation of nearly all four million slaves as the Union armies advanced, and committed the Union to ending slavery.
1863
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Enrollment Act / Draft Riots of 1863
The Enrollment Act of March 3, 1863, was legislation passed to provide fresh manpower for the Union Army. Conscription required the enrollment of every male citizen and those immigrants who had filed for citizenship between ages twenty and forty-five. Federal agents established a quota of new troops due from each congressional district. In some cities, particularly New York City, enforcement of the act sparked civil unrest as the war dragged on, leading to the New York Draft Riots on July 13-16.
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Juneteenth
Juneteenth, also known as Freedom Day or Emancipation Day, is a holiday in the United States honoring African-American heritage by commemorating the announcement of the abolition of slavery in the U.S. State of Texas in 1865. It is recognized as a state holiday or observance in 39 states.
1864
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13th Amendment
The Thirteenth Amendment to the United States Constitution officially abolished and continues to prohibit slavery and involuntary servitude, except as punishment for a crime. In response to this act, the modern prison industrial complex was officially begun.
Section 1. Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, or any place subject to their jurisdiction. Section 2. Congress shall have power to enforce this article by appropriate legislation.
1865
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The Bureau of Refugees, Freedmen & Abandoned Lands
The Freedmen's Bureau, part of the Department of War, and headed by General Oliver O. Howard, was a U.S. federal government agency to serve the needs of over 4 million freed slaves between 1865-1869 during the Reconstruction era. Initially intended to last for one year it provided legal food and housing, oversight, education, health care, and employment contracts with private landowners, it's mission was extended beyond the one year original mandate to focus on helping the freedmen by serving as a military court that handled post-slavery issues.
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Field Order 15
Special Field Orders, No. 15 provided for the confiscation of 400,000 acres along the Atlantic coast of South Carolina, Georgia, and Florida to be divided into 40-acre parcels to settle 18,000 freed slave families. The orders were issued following Sherman's March to the Sea. The orders were revoked by President Andrew Johnson resulting in the loss of thousands of acres of land, homes, crops and dreams of recently freed slaves.
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Civil Rights Act of 1871 (The Ku Klux Klan Act)
The Civil Rights Act of 1871, (enacted April 20) is a federal law in force to protect southern blacks from the Ku Klux Klan. This legislation was asked for by President U.S. Grant as a result of reports of widespread racial violence in the Deep South. The act gave the President the power to both intervene on violence and to suspend the right of habeas corpus. The result of the act was the virtual complete dismantlement of the KKK. The Act stated, "If any two or more persons within any State or Territory of the United States shall conspire together to overthrow, or to put down, or to destroy by force the government of the United States, or to levy war against the United States, or to oppose by force the authority of the government of the United States, or by force, intimidation, or threat to prevent, hinder, or delay the execution of any law, or go in disguise upon the public highway or upon the premises of another for the purpose, either directly or indirectly, of depriving any person or any class of persons of the equal protection of the laws, or of equal privileges or immunities under the laws, or for the purpose of preventing or hindering the constituted authorities of any State from giving or securing to all persons within such State the equal protection of the laws, each and every person so offending shall be deemed guilty of a high crime, and, upon conviction shall be punished by a fine not less than five hundred nor more than five thousand dollars, or by imprisonment, with or without hard labor, as the court may determine, for a period of not less than six months nor more than six years."
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Reconstruction 1865-1877
the term "Reconstruction Era" has two senses: the first covers the entire nation in the period 1865-1877 following the Civil War; the second one, describes the reconstruction of state and society in the former Confederacy from 1863 to 1877, with the. In battles between the president and Congress, the president prevailed until the election of 1866. At this time, a Republican coalition came to power and set out to use the Army and the Freedman's Bureau to transform former slaves into full citizens. Conservative white Democrats, alleging widespread corruption, counterattacked and regained power in each state by 1877, often with violence. The back-room negotiation for the Presidency of the United States that placed Rutherford B. Hayes in power in exchange for the pull out of federal troops from the south, is regarded by historians as the end of reconstruction.
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Andrew Johnson, Amnesty Proclamation, 29 May 1865
The amnesty proclamation by Andrew Johnson was meant to speed the return of full U.S. Citizenship for those who had joined the south and taken up arms against the Union. The Proclamation read: To the end, therefore, that the authority of the government may be restored, and that peace, order, and freedom may be established, I, ANDREW JOHNSON, do proclaim that I grant to all persons who have participated in the rebellion all rights of property, except as to slaves, but upon the condition, that every such person shall take and subscribe the following oath: I, _______ do solemnly swear, to God, that I will henceforth faithfully support, protect, and defend the Constitution of the United States, and the union of the States and that I will abide by the proclamations which have been made with reference to the emancipation of slaves.
1866
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The Southern Homestead Act
The Southern Homestead Act of 1866 is a federal law to break the cycle of debt during the Reconstruction period. Prior to this act, blacks and whites alike were having trouble buying land. This act attempted to solve this by selling land at low prices. the Southern Homestead Act opened up 46 million acres of public land in 160-acre plots in Alabama, Arkansas, Florida, Louisiana, and Mississippi. The primary beneficiaries for the first six months were freedmen who were in desperate need of land to till. The law was repealed ten years later.
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The Black Codes
The Black Codes were laws put in place in the United States after the Civil War with the effect of limiting the basic human rights and civil liberties and to control the labor, migration and other activities of newly-freed slaves and return them to their former state of subjugation and oppression. Black codes not only restricted the movement, freedoms and rights of blacks, but also ensured a steady supply of cheap labor for planters, municipal projects and for convict leasing by state prisons.
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Civil rights Act of 1866
Be it enacted that all persons born in the United States are hereby declared citizens, without regard to any previous condition of slavery or involuntary servitude, shall have the same right, in every State and Territory in the United States, to make and enforce contracts, to sue, be parties, and give evidence, to inherit, purchase, lease, sell, hold, and convey real and personal property, and to full and equal benefit of all laws and proceedings for the security of person and property, as is enjoyed by white citizens. And be it further enacted, That any person who shall subject any inhabitant of any State or Territory to the deprivation of any right shall be deemed guilty of a misdemeanor.
1867
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Reconstruction Acts, 4 acts
Fulfillment of the Acts were necessary for the former Confederate States to be readmitted to the Union. Congress feared that the Court might strike the Reconstruction Acts down as unconstitutional. To prevent this, Congress repealed the Habeas Corpus Act of 1867, revoking to the Supreme Court jurisdiction over the case.
- 1 Creation of 5 military districts in former confederacy (except Tennessee)
- 2 Congressional Approval needed for new State Constitutions
- 3 Confederate States would give voting rights to all men
- 4 All former Confederate States must ratify the 14th Amendment
1868
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The Impeachment of Andrew Johnson
After President Johnson notified Congress on February 21, 1868, that he had removed Edwin Stanton as Secretary of War and replaced him with Adjutant-General Lorenzo Thomas, it took the House of Representatives only three days to impeach him for "high crimes and misdemeanors." Meanwhile, Stanton refused to abandon his office and had Thomas arrested for attempting to exercise the duties of the Secretary of War. Johnson's trial in the Senate was presided over by Chief Justice Salmon B. Chase. There were eleven articles of impeachment. The 35-19 count was just one vote short of the necessary two-thirds majority and Johnson was acquitted.
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New Orleans Massacre
On July 30, 1866 at the Republican Convention 48 were killed, 166 were wounded including 10 policemen by an element loyal to the southern confederacy. Preparations for the massacre were made under the shield of the municipal authorities for some time before it took place. Fire-companies prepared and armed themselves; the police were withdrawn from their posts, supplied with revolvers, and kept waiting at their station-houses until the signal for the butchery was given, and then rushed to the bloody work with a raging mob of rebel soldiers. The elected officials of the city did nothing to stop the massacre.
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Fourteenth amendment:
This amendment was worded mostly the same as the civil rights act of 1866 and in response to the black codes. The redundancy of making the law a constitutional amendment was to prevent it from being legally challenged in court
All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.
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1870
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Fifteenth amendment
Section 1. The right of citizens of the United States to vote shall not be denied or abridged by the United States or by any State on account of race, color, or previous condition of servitude.
- Section 2. The Congress shall have power to enforce this article by appropriate legislation.
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Black Elected Officials During Reconstruction
On a per capita and absolute basis, more blacks were elected to public office during the period from 1865 to 1880 than at any other time in American history including a number of state legislatures which were effectively under the control of African American caucuses. These legislatures brought in programs that are considered part of government's role now, but at the time were radical, such as universal public education
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Enforcement Act of 1870
The Civil Rights Act of 1870 (The Enforcement Act) stated that, "all citizens of the United States who are or shall be otherwise qualified by law to vote at any election shall be entitled and allowed to vote at all such elections, without distinction of race, color, or previous condition of servitude"
The Enforcement act was legally challenged on the basis that the government did not have the authority to enforce it. In a unanimous opinion written by Justice Samuel Freeman Miller, the US Supreme Court concluded that the federal government "must have the power to protect the elections on which its existence depends from violence and corruption." Justice Miller stated that the Necessary and Proper Clause of Article I, Section 8, in conjunction with Article I, Section 4, which provides that "Congress may at any time make or alter" regulations regarding the "times, places, and manner of holding elections," granted Congress the necessary authority to pass the Enforcement Act.
1873
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Slaughterhouse Cases
The Slaughterhouse Cases, resolved by the U.S. Supreme Court in 1873, ruled that a citizen's "privileges and immunities," as protected by the Constitution's Fourteenth Amendment against the states, were limited to those spelled out in the Constitution and did not include many rights given by the individual states. Thus, a state may grant business monopolies to some of its citizens but not to others without running afoul of the Constitution. Slaughterhouse was the Court's first interpretation of the Fourteenth Amendment, arguably the most important addition to the Constitution after the Bill of Rights. The case began in 1869, when the Louisiana legislature passed a law creating and granting a monopoly to the Crescent City Livestock Landing & Slaughterhouse Company to slaughter animals in the New Orleans vicinity to be located downriver and across the river from New Orleans. Previously the New Orleans slaughterhouses had been located upriver of the city, and at times of low river flow, the cast off body parts of animals and their bowels would flow into the fresh water intake pipes for the city, leading to several cholera outbreaks. Louisiana claimed the measure promoted health and safety by centralizing and improving slaughterhouse production. Critics speculated the measure was designed to facilitate political patronage and to deny the original slaughterhouse operators their constitutional rights. After the state courts ruled that the law was constitutional, the butchers appealed to the U.S. Supreme Court, which decided the case in 1873.
The Supreme Court's decision, written by Justice Samuel Taylor Miller, ruled that the law did not violate the Fourteenth Amendment thus reducing the "privileges and immunity" clause to a dead-letter by stating that the clause only protected the rights of national citizenship and placed no new obligations on the states. This ruling left African American residents of the South powerless against discriminatory actions by state. The strong dissenting opinion by Justice Stephen J. Field, arguing that the Fourteenth Amendment protects the fundamental rights and liberties of all citizens against state interference.
1875
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Amnesty Act of 1875
The Amnesty Act of 1872 pardoned more than 150,000 former Confederate troops, restoring their right to vote and right to hold political offices. Following the passage of the law, only around 750 former Confederates were denied the right to hold office. Those 750 former soldiers were prohibited on the grounds laid out in the Fourteenth Amendment, that citizens having engaged in insurrection or rebellion shall not be allowed to hold any state of federal office.
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Civil Rights Act of 1875
It is essential that government recognize the equality of all men before the law mete out equal justice to all, of whatever nativity, race, color, or persuasion, religious or political. So be it enacted that all persons shall be entitled to the full and equal enjoyment of the accommodations, facilities, inns, public conveyances, theaters, and other places of public amusement regardless of any previous condition of servitude or race. And no citizen shall be disqualified for service as a juror on account of race, color, or previous condition of servitude
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The Mississippi Plan
On November 1, 1890 the state of Mississippi adopted a new constitution that held a clause known as the Mississippi Plan, which stated that black citizens were denied the right to vote because when they had been allowed to vote the state was overrun by corruption and fraud. The plan effectively disenfranchised almost all black voters by requiring six years of state citizenship, a $2.00 poll tax, a literacy and understanding test of the constitution, and no conviction of petty crime. Many believed that the legal disenfranchisement of blacks would cause a decrease in violence related to voting. The constitution was never voted on by the people of Mississippi, but was deemed valid by the Supreme Court in 1892 on the pretense that it was the will of the sovereign people of the state.
1876
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The South Carolina Civil Disturbances of 1876
The civil disturbances of 1876 were a series of race riots and civil unrest sparked by the gubernatorial election of 1876. They all occurred in counties where blacks were in the majority.
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Jim Crowe begins
The Jim Crow laws were state and local laws enacted between 1876 and 1965. They mandated segregation in all public facilities, with a supposedly "separate but equal" status for black Americans. Some examples of Jim Crow laws are the segregation of public schools, public places, and public transportation, and the segregation of restrooms, restaurants, and drinking fountains for whites and blacks. The U.S. military was also segregated. These Jim Crow Laws were separate from the 1800-€œ1866 Black Codes, which also restricted the civil rights and civil liberties of African Americans during slavery in slave-holding states. State-sponsored school segregation was declared unconstitutional by the Supreme Court of the United States in 1954 in Brown v. Board of Education, although it still existed. The remaining Jim Crow laws were overruled by the Civil Rights Act of 1964.
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United States v. Cruikshank
United States v. Cruikshank is the district court decision which was appealed to the Supreme Court. This case concerns an enforcement of rights under the fourteenth amendment including the first amendment right to assemble and second amendment right to arms. The Supreme Court decision held that these rights are not granted by the constitution and do not depend upon it for their existence. "When any of these rights and privileges are secured in the constitution of the United States only by a declaration that the state or the United States shall not violate or abridge them, it is at once understood that they are not created or conferred by the constitution, but that the constitution only guaranties that they shall not be impaired by the state, or the United States, as the case may be."
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United States v. Reese
In January 1873, two election inspectors, Hiram Reese and Matthew Foushee, refused to allow William Garner, an African-American, to vote in a municipal election in Lexington, Kentucky. Reese and Foushee claimed Garner had failed to pay a tax of $1.50, but Garner had attempted to pay the tax and was refused by a tax collector. The Enforcement Act of 1870, which defined penalties associated with violations of voting rights under the Fifteenth Amendment, stipulated that if an official refused to permit a citizen to perform an action required for voting, the citizen could present an affidavit that would qualify him. Reese and Foushee refused to accept Garner's affidavit. Reese and Foushee were charged with violating the Enforcement Act. On appeal, in an 8-1 decision authored by Chief Justice Morrison Waite, the Circuit Court of the United States concluded that the relevant sections of the Enforcement Act lacked the necessary, limiting language to qualify as enforcement of the Fifteenth Amendment. The Chief Justice first stated that the Fifteenth Amendment "does not confer the right of suffrage upon any one," but "prevents the States, or the United States, however, from giving preference to one citizen of the United States over another on account of race, color, or previous condition of servitude." In examining the language of the Enforcement Act, the Court noted that, while the first two sections of the act explicitly referred to race in criminalizing interference with the right to vote, the relevant third and fourth sections refer only to the "aforesaid" offense. According to the Court, this language does not sufficiently tailor the law to qualify as "appropriate legislation" under the Enforcement Clause of the Fifteenth Amendment.
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