delivered by Justice Bradley, the court struck down part of the Civil Rights Act of 1875, holding that the Equal Protection Clause and the Thirteenth Amendment do not protect against racial discrimination by private actors. The decision has not been overturned, and most future legislation against private discrimination (such as the Civil Rights Act of 1964) was passed on the basis of the Commerce Clause. Elk v. Wilkins (1884): In a 7–2 decision delivered by Justice Gray, the court held that the Citizenship Clause does not automatically grant citizenship to Native Americans born on Indian reservations. The case was effectively overruled by the passage of the Indian Citizenship Act in 1924. The Railroad Commission Cases (1886): In a 6-2 decision delivered by Chief Justice Waite, the court upheld state fixation of railroad prices as a permissible exercise of police power. Chicago, Milwaukee & St. Paul Railway Co. v. Minnesota (1890) later limited the effect of this ruling. Wabash, St. Louis & Pacific Railway Co. v. Illinois (1886): Santa Clara County v. Southern Pacific Railroad Co. (1886): Presser v. Illinois (1886): In a decision delivered by Justice Woods, the court affirmed its decision in Cruikshank, saying that the First and Second Amendments do not apply to state governments. The decision overturned the conviction of Herman Presser, a member of Lehr und Wehr Verein, a Chicago-based socialist military organization. The Telephone Cases (1888): In a series of court cases related to the invention of the telephone, the court upheld Alexander Graham Bell's patents against the claims of Western Union. The court split, 4–3, on the ruling, and Chief Justice Waite delivered the majority opinion. Judicial philosophy The Waite Court confronted constitutional questions arising from the Civil War, Reconstruction, the expansion of the federal government following the Civil War, and the emergence of a national economy linked together by railroads. The Waite Court issued several major decisions, including Cruikshank, that denied the federal government the power to protect the civil rights of African Americans. However, historian Michael Les Benedict notes that the civil rights decision were made during the era of dual federalism, and the Waite Court was sincerely concerned with maintaining the balance of power between the federal government and state governments. While the Waite Court struck down civil rights laws, it upheld many economic regulations, in contrast with the Fuller Court. References Further reading Pdf 1880s in the United States United