United States v. Cruikshank
United States v. Cruikshank is a significant Supreme Court case from the Reconstruction era concerning civil rights and federal authority. The case emerged following the Colfax massacre in 1873, where a white mob attacked a gathering of Black individuals in Louisiana, resulting in approximately one hundred deaths. Federal prosecutors sought to hold the perpetrators accountable through the Enforcement Act of 1870, which made it a federal offense to conspire against the constitutional rights of individuals. However, the Supreme Court ruled unanimously that the indictments against William Cruikshank and others were invalid, primarily highlighting the distinction between state and national citizenship rights.
Chief Justice Morrison R. Waite emphasized that federal protection of civil rights applied only to actions taken by state officials, not to acts committed by private individuals. The ruling ultimately restricted federal intervention in civil rights matters, placing the onus of protecting Black citizens' rights largely on southern states, many of which were unsympathetic to their plight. This case reflects the broader national sentiment of the time, which had grown weary of federal involvement in southern politics, significantly impacting the civil rights landscape for African Americans during the post-Civil War period.
United States v. Cruikshank
Date: March 27, 1876
Citation: 92 U.S. 542
Issues: Federal enforcement of civil rights; states’ rights
Significance: Based on narrow interpretations of the Fourteenth and Fifteenth Amendments, the Supreme Court severely limited the authority of the federal government to protect the civil rights of African Americans.
Because state courts rarely prosecuted acts of violence against the freed slaves of the South, the Enforcement 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.
The Supreme Court unanimously held that the indictments were invalid. In a complicated ruling, Chief Justice Morrison R. Waite 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.