On Easter Sunday in 1873, the White League, a paramilitary organization, shot approximately 100 black state militia members in a clash over a contested gubernatorial election in Louisiana. Three White League members died in the battle known as the Colfax Massacre. Approximately 100 members were charged with felony conspiracy to deny an individual’s constitutional rights. Nine of them were tried, but all were set free without penalty.

The Supreme Court’s decision related to the Colfax Massacre effectively ended Reconstruction. The ruling held that the Due Process and Equal Protection clauses of the 14th Amendment applied only to the actions of states—not individuals. It wasn’t until the civil rights movement of the 1960s that the Federal Government resumed efforts to protect African Americans in the South.