that such democracies have ever been spectacles of turbulence and contention; have ever been found incompatible with personal security or the rights of property; and have in general been as short in their lives as they have been violent in their deaths." A political crisis in 1840s Rhode Island, the Dorr Rebellion, forced the Supreme Court to rule on the meaning of this clause. At the time, the Rhode Island constitution was the old royal charter established in the 17th century. By the 1840s, only 40% of the state's free white males were enfranchised. An attempt to hold a popular convention to write a new constitution was declared insurrection by the charter government, and the convention leaders were arrested. One of them brought suit in federal court, arguing that Rhode Island's government was not "republican" in character, and that his arrest (along with all of the government's other acts) was invalid. In Luther v. Borden, the Court held that the determination of whether a state government is a legitimate republican form as guaranteed by the Constitution is a political question to be resolved by the Congress. In effect, the court held the clause to be nonjusticiable. The Luther v. Borden ruling left the responsibility to establish guidelines for the republican nature of state governments in the hands of the Congress. This power became an important part of Reconstruction after the American Civil War. The Radical Republican majority used this clause as the basis for taking control of the ex-Confederate states and for promoting civil rights for freedmen, plus the limiting of political and voting rights for ex-Confederates, abolishing the ex-Confederate state governments, setting guidelines for the readmission of the rebellious states into the Union. In 1912, Luther was reaffirmed in Pacific States Telephone and Telegraph Co. v. Oregon. In Pacific States, a utility company challenged an Oregon tax law passed by a referendum, as opposed to the ordinary legislative process. The utility company claimed that the use of referendums, as a form of direct democracy, violated the republican form of government clause, which permits only a representative democracy. The court rejected the challenge, finding the challenge to have presented a nonjusticiable political question that only Congress can resolve. The doctrine was later limited in Baker v. Carr (1962), which held that the lack of state legislative redistricting to be justiciable. While the Supreme Court's holding in Luther v. Borden still