the enforcement of the Privileges or Immunities Clause as an express limitation upon the powers of the States. The rights and privileges of a citizen of the United States were defined by Congress in the Civil Rights Act of 1866: Subsequently, on April 28, 1866, the Joint Committee of Fifteen voted in favor of a second draft proposed by Congressman Bingham, which would ultimately be adopted into the Constitution. The Joint Committee no longer tracked the existing language in Article Four as the Committee had previously done. On May 10, 1866, in the closing debate on the House floor, Bingham nevertheless quoted Article IV: The Fourteenth Amendment was approved by the House later that day. Michigan Senator Jacob M. Howard introduced the amendment in the Senate, and gave a speech in which he discussed the meaning of this clause. Howard noted that the U.S. Supreme Court had never squarely addressed the meaning of the Privileges and Immunities Clause in Article IV, which therefore made the effect of the new Privileges or Immunities Clause somewhat uncertain. Congress gave final approval to the Privileges or Immunities Clause when the House proposed the Fourteenth Amendment to the states for ratification on June 13, 1866. There was much discussion of this proposed clause as the amendment awaited ratification by the states. For example, according to a November 15, 1866 pseudonymous letter published in the New York Times: "[N]o State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States." This is intended for the enforcement of the Second Section of the Fourth Article of the Constitution, which declares that "the citizens of each State shall be entitled to all the privileges and immunities of the citizens in the several States. We have seen, in the first number, what privileges and immunities were intended. The same authorities have held that the negro of African descent was not a citizen within the meaning of the term, as used in this and other articles of the Constitution; that he was not one of the "peoples" who ordained that sacred charter; that as a slave he was only three-fifth of a "number," but as a free man he was a whole number to be counted for representation, and a whole "person," who might be held to involuntary "service," and reclaimed in any State to which he might escape. The