In Miles v. Caldwell, the United States Supreme Court considered a case involving an African American man named John Miles who was arrested and charged with vagrancy in Virginia. The court held that the state of Virginia had violated his rights under the Thirteenth Amendment by arresting him without due process of law. The court found that since he had not been convicted or sentenced for any crime, he could not be lawfully detained and must be released from custody immediately. Furthermore, it determined that states cannot pass laws which are intended to oppress people based on their race or color as this would violate both the Thirteenth Amendment and equal protection clause of the Fourteenth Amendment. This decision set a precedent for future cases regarding civil liberties violations against African Americans during Reconstruction era America.

In Miles v. Caldwell, the Supreme Court of the United States ruled that a state law which prohibited African Americans from entering into contracts with white persons was unconstitutional. The majority opinion held that this law violated both the Thirteenth Amendment and Article IV of the Constitution, which prohibits states from passing laws impairing contractual obligations. In his dissenting opinion, Justice Field argued that while he agreed with much of what was said in the majority opinion regarding slavery and its effects on African Americans' rights to contract freely, he disagreed with their conclusion about whether or not this particular state law should be struck down as unconstitutional. He argued that it did not violate either amendment because it only applied to contracts between whites and blacks; thus, it did not interfere with any other person's right to enter into such agreements. Furthermore, Justice Field contended that if Congress had intended for all racial discrimination against African Americans in contracting matters to be prohibited by these amendments then they would have explicitly stated so in them rather than leaving it up for interpretation by courts like this one.