Landmark Case

United States v. Cruikshank (1876)

In a case arising from the 1873 Colfax massacre, during which more than 125 Black people were murdered by white supremacists, the Supreme Court ruled that the 14th Amendment only applied to state action, not to persons acting individually.

"The Louisiana Murders—Gathering The Dead And Wounded." Published in Harper's Weekly May 10, 1873, page 397 after the Colfax massacre in Colfax on April 13, 1873. (Public domain.)