Fox (1877), the Court held that the criminal bankruptcy fraud statute exceeded Congress's powers under the Necessary and Proper Clause. Civil rights In United States v. Cruikshank (1875), the Court overturned a conviction under the civil rights crime statute, holding that the First and Second Amendment were not incorporated against the states and the Fourteenth Amendment only applied to state action. In United States v. Reese (1875), the Court overturned another civil rights conviction for depriving African-Americans of the right to vote, holding that the statute was void for vagueness as applied to voter suppression. In United States v. Harris (1883), known as the Ku Klux Case, the Court invalidated as unconstitutional the civil rights crime statute that applied to conspiracies to deprive state-law rights and privileges. But, in United States v. Gale (1883), the Court upheld a statute that punished state officers for misconduct in federal Congressional elections. And, in United States v. Waddell (1884), the Court upheld a criminal civil rights law as applied to the rights of Homesteaders. In Ex parte Virginia (1880) and Ex parte Siebold (1879), the Court held that the civil rights crime statute was a valid exercise of Congress's power under the Thirteenth and Fourteenth Amendments. In The Ku Klux Cases (1884), the Court upheld a conviction for a conspiracy to prevent voters from voting for federal officials, finding a relevant constitutional right. Counterfeiting In United States v. Carll (1881), the Court defined the mens rea required under the counterfeiting statute. In Ex parte Carll (1883), the Court held that the offense of counterfeiting was stated where the name of the original payee had been erased and replaced. In United States v. Arjona (1887), the Court upheld the constitutionality of a prohibition on counterfeiting the notes of foreign banks and corporations under the Foreign Commerce Clause and the law of nations power. Embezzlement In United States v. Britton (1883), the Court issued four opinions on the subject of the misapplication of public funds. In United States v. Smith (1888), the Court held that the clerk of the Collector of Customs was not a public officer and thus was not indictable for embezzlement. Extortion under color of office Section 12 of the Crimes Act of 1825 punished extortion under color of office: Every officer of the United States who is guilty of extortion under color of his office shall be punished by a fine