Chief Justice Waite, in United States v. Cruikshank (1876), ruled that the Enforcement Act violated states’ rights. Moreover, the only recourse the federal government could take was the Fourteenth Amendment, but, he continued, that did not cover vigilantes or private acts of terror, but rather covered only those acts of violence carried out by the states. The ruling not only let mass murderers go free; it effectively removed the ability of the federal government to rein in anti-black domestic terrorism moving forward.107
