United States v. Cruikshank was a United States Supreme Court case that addressed the scope of the federal government’s power to protect civil rights. The case arose from the Colfax Massacre, a violent attack on African Americans in Louisiana in 1873. The defendants, William Cruikshank and other members of a white supremacist group, were charged with violating the civil rights of African Americans by conspiring to prevent them from exercising their right to bear arms. The Supreme Court held that the federal government did not have the power to protect civil rights under the Enforcement Act of 1870, which was the basis of the charges against the defendants. The Court reasoned that the federal government’s power to protect civil rights was limited to those rights specifically enumerated in the Constitution, and the right to bear arms was not one of those rights. The Court also held that the federal government could not use the Enforcement Act to prosecute private individuals for violating the civil rights of others. The decision in United States v. Cruikshank was widely criticized for limiting the federal government’s power to protect civil rights. The decision was eventually overturned by the Civil Rights Cases of 1883, which held that the federal government had the power to protect civil rights under the Fourteenth Amendment.

In United States v. Cruikshank, the Supreme Court held that the Second Amendment does not protect individuals from state infringements on their right to bear arms. The dissenting opinion argued that this decision was contrary to both the text and intent of the Second Amendment. Justice Field wrote in his dissent that Congress had no authority under Article I of the Constitution to regulate or restrict a citizen's right to keep and bear arms; rather, it is an individual right protected by "the full scope of liberty" guaranteed by Amendments IX and X. He further noted that while states may have some power over firearms regulation, they cannot deny citizens' rights without due process as provided for in Amendment XIV. Finally, he argued that any attempt by a state government to interfere with an individual's ability to exercise their constitutional rights should be subject to judicial review so as not violate those same rights.