United States v. Cruikshank facts for kids
Quick facts for kids United States v. Cruikshank |
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| Argued March 30 – June 24, 1875 Decided March 27, 1876 |
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| Full case name | United States v. Cruikshank, et al. |
| Citations | 92 U.S. 542 (more)
2 Otto 542; 23 L. Ed. 588; 1875 U.S. LEXIS 1794
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| Holding | |
| The right of assembly under the First Amendment and the right to bear arms under the Second Amendment are only applicable to the federal government, not the states or private actors. | |
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| Majority | Waite, joined by Swayne, Miller, Field, Strong |
| Concur/dissent | Clifford, joined by Davis, Bradley, Hunt |
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Overruled by
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United States v. Cruikshank was a very important decision by the Supreme Court of the United States. It happened in 1876. The Court decided that the Bill of Rights did not limit what state governments or private groups could do. This was even after the Fourteenth Amendment was added.
This ruling overturned some federal convictions. These convictions were related to events that happened during the Reconstruction Era. This was a time after the American Civil War. The case was a big setback for efforts to protect the rights of African Americans during that period.
What Led to This Case?
The case came from a very disputed election in Louisiana in 1872. After the election, a violent event known as the Colfax massacre took place. During this event, many people died.
Federal charges were brought against some individuals. They were charged under a law called the Enforcement Act of 1870. This law made it illegal for two or more people to conspire to take away someone's constitutional rights.
The charges included stopping people from using their First Amendment right to gather peacefully. They were also accused of stopping people from using their Second Amendment right to own guns.
The Court's Important Decision
Chief Justice Morrison Waite wrote the main opinion for the Court. He decided to overturn the earlier convictions. He said that the people involved had to rely on Louisiana state courts for protection.
Chief Justice Waite ruled that neither the First Amendment nor the Second Amendment limited the powers of state governments. He also said they did not limit what individuals could do.
He further explained that parts of the Fourteenth Amendment, like the Due Process Clause and the Equal Protection Clause, only limited state governments. They did not limit the actions of individuals.
This decision meant that African Americans in the South were left without strong federal protection. They had to rely on state governments. These governments were often controlled by white leaders who were not supportive of their rights. This allowed groups who used violence to continue to stop black citizens from voting.
How This Case Changed Later
Cruikshank was the first time the Supreme Court looked at a possible violation of the Second Amendment. Many years after this case, the Supreme Court started to apply the Bill of Rights to state governments. This process is called incorporation.
For example, the Court applied the First Amendment's freedom of assembly to states in the case of De Jonge v. Oregon (1937). Much later, the Second Amendment was applied to states in the case of McDonald v. City of Chicago (2010). This showed that the ideas from Cruikshank were eventually changed by later court decisions.
