Bradwell a license to practice law was not a violation of the U.S. Constitution and refused to extend federal authority in support of women's citizenship rights. In Minor v. Happersett the U.S. Supreme Court ruled that the Privileges or Immunities Clause of the Fourteenth Amendment did not provide voting rights to U.S. citizens; it only guaranteed additional protection of privileges to citizens who already had them. If a state constitution limited suffrage to male citizens of the United States, then women in that state did not have voting rights. After U.S. Supreme Court decisions between 1873 and 1875 denied voting rights to women in connection with the Fourteenth and Fifteenth Amendments, suffrage groups shifted their efforts to advocating for a new constitutional amendment. Continued settlement of the western frontier, along with the establishment of territorial constitutions, allowed the women's suffrage issue to be raised as the western territories progressed toward statehood. Through the activism of suffrage organizations and independent political parties, women's suffrage was included in the constitutions of Wyoming Territory (1869) and Utah Territory (1870). Women's suffrage in Utah was revoked in 1887, when Congress passed the Edmunds-Tucker Act in 1887 that also prohibited polygamy; it was not restored in Utah until it achieved statehood in 1896. Post-Reconstruction (1878–1910) Existing state legislatures in the West, as well as those east of the Mississippi River, began to consider suffrage bills in the 1870s and 1880s. Several held voter referendums, but they were unsuccessful until the suffrage movement was revived in the 1890s. Full women's suffrage continued in Wyoming after it became a state in 1890. Colorado granted partial voting rights that allowed women to vote in school board elections in 1893 and Idaho granted women suffrage in 1896. Beginning with Washington in 1910, seven more western states passed women's suffrage legislation, including California in 1911, Oregon, Arizona, and Kansas in 1912, Alaska Territory in 1913, and Montana and Nevada in 1914. All states that were successful in securing full voting rights for women before 1920 were located in the West. A federal amendment intended to grant women the right to vote was introduced in the U.S. Senate for the first time in 1878 by Aaron A. Sargent, a Senator from California who was a women's suffrage advocate. Stanton and other women testified before the Senate in support of the amendment. The proposal sat in a committee until it was considered