In the United States v. Harris case of 1899, the U.S. Supreme Court ruled that a federal law punishing conspiracies to deprive individuals of their civil rights was unconstitutional because it exceeded Congress's powers under the Fourteenth Amendment. The case involved four white men who were charged with conspiring to prevent an African American man from exercising his right to vote in a Tennessee election by violently assaulting and injuring him. They appealed their convictions on grounds that they had been prosecuted under an invalid law - specifically, Section 5508 of the Revised Statutes which made it illegal for two or more people to conspire together with intent to deny anyone equal protection of laws or due process. The court agreed with them, stating that while states are prohibited from denying equal protection under laws, private individuals are not covered by this prohibition unless there is state action involved.

In the dissenting opinion for United States v. Harris, 1899, Justice Harlan argued that the majority's decision to strike down part of the Enforcement Act of 1870 was a misinterpretation of both constitutional law and legislative intent. He contended that Congress had clear authority under the Fourteenth Amendment to protect citizens from violence perpetrated by private individuals as well as state actors. Furthermore, he believed that this power extended not only to acts directly infringing upon civil rights but also those indirectly doing so through intimidation or threat. In his view, allowing states exclusive jurisdiction over such crimes would effectively nullify federal protection against racial discrimination because Southern states were unlikely to prosecute white perpetrators adequately due to prevailing racial prejudices at that time.