labeled as theft, leading to arrest and involuntary labor. Some states explicitly curtailed Black people's right to bear arms, justifying these laws with claims of imminent insurrection. In Mississippi and Alabama, these laws were enforced through the creation of special militias. Historian Samuel McCall, who published a biography of abolitionist Thaddeus Stevens, commented in 1899 that the Black Codes had "established a condition but little better than that of slavery, and in one important respect far worse": by severing the property relationship, they had diminished the incentive for property owners to ensure the relative health and survival of their workers. Regarding the question of whether Southern legislatures deliberately tried to maintain white supremacy, Beverly Forehand writes: "This decision was not a conscious one on the part of white legislators. It was simply an accepted conclusion." During Reconstruction, state legislatures passed some laws that established some positive rights for freedmen. States legalized Black marriages and in some cases increased the rights of freedmen to own property and conduct commerce. Reconstruction and Jim Crow The Black Codes outraged public opinion in the North because it seemed the South was creating a form of quasi-slavery to negate the results of the war. When the Radical 39th Congress re-convened in December 1865, it was generally furious about the developments that had transpired during Johnson's Presidential Reconstruction. The Black Codes, along with the appointment of prominent Confederates to Congress, signified that the South had been emboldened by Johnson and intended to maintain its old political order. Railing against the Black Codes as returns to slavery in violation of the Thirteenth Amendment, Congress passed the Civil Rights Act of 1866, the Fourteenth Amendment, and the Second Freedmen's Bureau Bill. The Memphis Riots in May 1866 and the New Orleans Riot in July brought additional attention and urgency to the racial tension state-sanctioned racism permeating the South. After winning large majorities in the 1866 elections, the Republican Congress passed the Reconstruction Acts placing the South under military rule. This arrangement lasted until the military withdrawal arranged by the Compromise of 1877. In some historical periodizations, 1877 marks the beginning of the Jim Crow era. The 1865–1866 Black Codes were an overt manifestation of the system of white supremacy that continued to dominate the American South. Historians have described this system as the emergent result of a wide variety of laws and practices, conducted on all levels of