There was no possibility the culprits would be prosecuted under local laws. Invoking the Enforcement Act of 1870, a federal grand jury handed down seventy-two indictments, but only three men were convicted. In 1876, in United States v. Cruikshank, the Supreme Court determined that the perpetrators could not be prosecuted under the Fourteenth Amendment because it governed only state actions, not individual ones. The Colfax murderers thus walked off scot-free, sending a powerful message to white supremacists that they could slay blacks without any penalty.
