Pennsylvania: February 6, 1867 Rhode Island: February 7, 1867 Wisconsin: February 13, 1867 Massachusetts: March 20, 1867 Nebraska: June 15, 1867 Iowa: March 16, 1868 Arkansas: April 6, 1868 Florida: June 9, 1868 North Carolina: July 4, 1868 (after rejection December 14, 1866) Louisiana: July 9, 1868 (after rejection February 6, 1867) South Carolina: July 9, 1868 (after rejection December 20, 1866) If rescission by Ohio and New Jersey were illegitimate, South Carolina would have been the 28th state to ratify the amendment, enough for the amendment to be a part of the Constitution. Otherwise, only 26 states ratified the amendment out of the needed 28. Ohio and New Jersey's rescissions (which occurred after Democrats retook the states legislature) caused significant controversy and debate, but as this controversy occurred ratification by other states continued: On July 20, 1868, Secretary of State William H. Seward certified that if withdrawals of ratification by New Jersey and Ohio were illegitimate, then the amendment had become part of the Constitution on July 9, 1868, with ratification by South Carolina as the 28th state. The following day, Congress declared New Jersey's recession of the amendment "scandalous", rejected the act and then adopted and transmitted to the Department of State a concurrent resolution declaring the Fourteenth Amendment to be a part of the Constitution and directing the Secretary of State to promulgate it as such, thereby establishing a precedent that a state cannot rescind a ratification. Ultimately, New Jersey and Ohio were named in the congressional resolution as having ratified the amendment, as well as Alabama, making 29 states in total. On the same day, one more State ratified: On July 27, Secretary Seward received the formal ratification from Georgia. The following day, July 28, Secretary Seward issued his official proclamation certifying the adoption of the Fourteenth Amendment. Secretary Seward stated that his proclamation was "in conformance" to the resolution by Congress, but his official list of States included both Alabama and Georgia, as well as Ohio and New Jersey. Ultimately, regardless of the legal status of New Jersey's and Ohio's rescission, the amendment would have passed at the same time because of Alabama and Georgia's ratifications. The inclusion of Ohio and New Jersey has led some to question the validity of the rescission of a ratification. The inclusion of Alabama and Georgia has called that conclusion into question. While there have been Supreme Court cases