7–2 decision delivered by Chief Justice Waite, the court held that the Fifteenth Amendment does not prevent states from using ostensibly race-neutral limitations on voting rights such as poll taxes, grandfather clauses, and literacy tests. The decision played a major role in allowing states to effectively disenfranchise African-Americans. Minor v. Happersett (1875): In a unanimous decision written by Chief Justice Waite, the court held that the Constitution did not grant women the right to vote. The ruling was effectively overturned by the ratification of the Nineteenth Amendment in 1920. United States v. Cruikshank (1875): In a 9–0 decision delivered by Chief Justice Waite, the court overturned indictments arising from the Colfax massacre. The court held that the Due Process Clause and the Equal Protection Clause only apply to state action, and that the Fourteenth Amendment had not incorporated the First or Second amendments to apply to the states. The decision was a major blow to the power of the Enforcement Acts and the federal government's ability to protect the rights of African-Americans in the South. Later decisions, including Gitlow v. New York (1925), would incorporate most of the Bill of Rights to apply to states. Reynolds v. United States (1878): In a decision delivered by Chief Justice Waite, the court upheld the conviction of George Reynolds. Reynolds, a member of the LDS Church, had been convicted of bigamy under the Morrill Anti-Bigamy Act. The court held that the banning of bigamy did not conflict with the Establishment Clause. Pennoyer v. Neff (1878): In a decision written by Justice Field, the court held that a state can exert personal jurisdiction over a defendant if the defendant is served notice while physically present in a state. Strauder v. West Virginia (1880): In a 7–2 decision delivered by Justice Strong, the court held that the Equal Protection Clause bans exclusionary policies that lead to all-white juries. The decision overturned the conviction of Taylor Strauder, an African-American convicted of murder in West Virginia by an all-white jury. Strauder was the first time that the Court reversed a state criminal conviction for a violation of a constitutional provision concerning criminal procedure. Pace v. Alabama (1883): In a unanimous decision delivered by Justice Field, the court upheld Alabama's anti-miscegenation laws. Pace was later overruled by Loving v. Virginia (1967) on the basis of the Equal Protection Clause. The Civil Rights Cases (1883): In an 8–1 decision