The Chinese Struggle for Civil Rights in 19th-century America: The Unusual Case of Baldwin v. Franks

In its October term 1882, the United States Supreme Court handed down a decision which aborted federal efforts to deal with anti-black violence in the states of the old Confederacy. At issue in the case of United States v. Harris was the constitutionality of a federal statute, Section 5519 of the Revised Statutes of the United States of 1874, which made it a crime for private persons to conspire to deprive other individuals of the equal protection of the laws. A group of white Tennesseeans had been convicted under the statute for assaulting and badly beating a group of black criminal defendants in the custody of local authorities. The court held that there was no foundation in the Constitution for the federal law and voided it, thus overturning the convictions. The 14th Amendment, the purported basis for the statute, was aimed, according to the court, at state action and did not empower Congress to legislate against purely private conduct. It was the same line of reasoning that would lead the court in its following term, in the celebrated Civil Rights Cases, to declare unconstitutional Section 1 of the Civil Rights Act of 1875, which established civil and criminal penalties for racially motivated interference with anyone's full and equal enjoyment of public accommodations and conveyances.