The Cruikshank case arose from the 1873 Colfax Massacre, in which a group of armed whites killed more than a hundred African American men as a result of a political dispute. Three men convicted of violating the 1870 Enforcement Act – a law aimed primarily at curbing Ku Klux Klan violence that forbade conspiracies to deny the constitutional rights of any citizen – appealed on the grounds that their indictments were insufficient. When the case reached the Supreme Court, the Court sided with the defendants, holding that the rights they were alleged to have violated were not enforceable in this case. The First and Second Amendment rights to assembly and the bearing of arms were, according to the Court’s ruling, intended only to restrict the actions of the federal government and did not apply to the states or private citizens, and the Fourteenth Amendment rights to due process and equal protection applied only to state action and again, not to the actions of individuals. The Court’s decision was further evidence of its narrow interpretation of the Fourteenth Amendment as well as the federal government’s diminishing focus on Reconstruction.
March 27, 1876