address how a legislature must treat its own citizens. Another pertinent federal circuit court case was decided by Justice Henry Baldwin, who succeeded Justice Washington. In the case of Magill v. Brown, Justice Baldwin addressed the Privileges and Immunities Clause: "We must take it therefore as a grant by the people of the state in convention, to the citizens of all the other states of the Union, of the privileges and immunities of the citizens of this state." These federal circuit court statements by Justices Washington and Baldwin were not inconsistent with each other. They both became the settled doctrine of the U.S. Supreme Court after the Civil War. In 1833, Justice Joseph Story also addressed the clause: It is obvious, that, if the citizens of each state were to be deemed aliens to each other, they could not take, or hold real estate, or other privileges, except as other aliens. The intention of this clause was to confer on them, if one may so say, a general citizenship; and to communicate all the privileges and immunities, which the citizens of the same state would be entitled to under the like circumstances. Thus, Story thought that the clause was meant "only to provide temporary visitors with equality in certain rights with the citizens of the states they were visiting." The clause was also mentioned by the Supreme Court in the infamous Dred Scott v. Sandford decision in 1857. Chief Justice Taney, speaking for the majority, said that the clause gives state citizens, when in other states, the right to travel, the right to sojourn, the right to free speech, the right to assemble, and the right to keep and bear arms." In his dissent, Justice Curtis wrote that the clause does not confer any rights other than rights that a visited state chooses to guarantee to its own citizens. After the Civil War In 1866, during the congressional debates about the draft Fourteenth Amendment to the United States Constitution, Senator Jacob Howard noted that the U.S. Supreme Court had never squarely addressed the meaning of the Privileges and Immunities Clause: It would be a curious question to solve what are the privileges and immunities of citizens of each of the States in the several States....I am not aware that the Supreme Court have ever undertaken to define either the nature or extent of the privileges and immunities thus guarantied. The