The Thirteenth Amendment ended slavery and African American slaves gained their freedom during the Civil War; however, this did not mean they were fully integrated into American society. After the war, Southern Whites faced a crisis. The emancipation of slaves and the Fourteenth Amendment’s guarantee of citizenship undermined their assertion that citizenship was for Whites only. The clear line between Whites who ruled and Blacks who were ruled became vulnerable. Since Whites slave owners could no longer treat the former slaves as non-citizens, they sought to strengthen this distinction by restoring slavery as best they could. Imposing disabilities on Black civil rights that limited their access to full citizenship was a goal to reach. Within months of the Civil War’s end, former Confederate states passed Black Codes to regulate the behavior of the former slaves as well as their status. Congressional Reconstruction was still a year away, and white Democrats who governed state legislatures passed laws that restricted the liberty of the former slaves. Although Black Codes granted African American certain rights such as legalized marriage, ownership of property; the laws prohibited interracial marriage for the fear of weakening the White race, denied them the rights to testify against Whites in court, jury service and the right to vote. The Black Codes also forced African Americans to labor and constrained their freedom of movement. Individuals not under control of white land owners through labor contracts became criminals, and were put under the control of the convict labor system. This was permitted because the Thirteenth Amendment sanctioned enslavement as a punishment for crimes.

Reacting to the Black Codes, Congress guaranteed citizenship for all former slaves through the Fourteenth Amendment. However, this amendment did not specify that the right to vote was a