state of Georgia ignored the Supreme Court's decision in Worcester v. Georgia. President Andrew Jackson, who sided with the Georgia courts, is supposed to have remarked, "John Marshall has made his decision; now let him enforce it!" Some state governments in the South also resisted the desegregation of public schools after the 1954 judgment Brown v. Board of Education. More recently, many feared that President Nixon would refuse to comply with the court's order in United States v. Nixon (1974) to surrender the Watergate tapes. Nixon ultimately complied with the Supreme Court's ruling. Supreme Court decisions can be purposefully overturned by constitutional amendment, something that has happened on six occasions: Chisholm v. Georgia (1793) – overturned by the Eleventh Amendment (1795) Dred Scott v. Sandford (1857) – overturned by the Thirteenth Amendment (1865) and the Fourteenth Amendment (1868) Pollock v. Farmers' Loan & Trust Co. (1895) – overturned by the Sixteenth Amendment (1913) Minor v. Happersett (1875) – overturned by the Nineteenth Amendment (1920) Breedlove v. Suttles (1937) – overturned by the Twenty-fourth Amendment (1964) Oregon v. Mitchell (1970) – overturned by the Twenty-sixth Amendment (1971) When the court rules on matters involving the interpretation of laws rather than of the Constitution, simple legislative action can reverse the decisions (for example, in 2009 Congress passed the Lilly Ledbetter Fair Pay Act of 2009, superseding the limitations given in Ledbetter v. Goodyear Tire & Rubber Co. in 2007). Also, the Supreme Court is not immune from political and institutional consideration: lower federal courts and state courts sometimes resist doctrinal innovations, as do law enforcement officials. In addition, the other two branches can restrain the court through other mechanisms. Congress can increase the number of justices, giving the president power to influence future decisions by appointments (as in Roosevelt's Court Packing Plan discussed above). Congress can pass legislation that restricts the jurisdiction of the Supreme Court and other federal courts over certain topics and cases: this is suggested by language in Section 2 of Article Three, where the appellate jurisdiction is granted "with such Exceptions, and under such Regulations as the Congress shall make." The court sanctioned such congressional action in the Reconstruction Era case ex parte McCardle (1869), although it rejected Congress' power to dictate how particular cases must be decided in United States v. Klein (1871). On the other hand, through its power of judicial review, the Supreme Court has