id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cjrl-11662	Carle, Susan	Reconstruction's Lessons	2023	56	.pdf	application/pdf	31519	1194	49	For example, a handful of states, including New York and Minnesota, passed state civil rights statutes modeled on the Civil Rights Act of 1875, and advocates brought a few successful cases under these laws.246 They also won several Supreme Court civil rights cases, though these cases at first changed little on the ground.247 T. Thomas Fortune, son of Florida Reconstruction politician Emmanuel Fortune and educated in Freedmen’s Bureau schools, articulated the idea that became the template for a series of organizations intended to provide a national nonpartisan structure for racial justice reform.248 These organizations, which grew directly out of Black abolitionists’ meetings in the 1830s and beyond, included the Afro American League, the Afro American Council, and the Niagara Movement, which then flowed into the founding of the NAACP in 1910.249 Id. Note how this logic further narrowed the scope of the Fourteenth Amendment so that denial of rights by state officials, exercising discretion granted them under state law, could not constitute state action where discrimination was not patent on the face of the law.	cache/cjrl-11662.pdf	txt/cjrl-11662.txt