housing, the number of sundown towns has decreased. However, as sociologist James W. Loewen writes in his book, Sundown Towns: A Hidden Dimension of American Racism (2005), it is impossible to precisely count the number of sundown towns at any given time, because most towns have not kept records of the ordinances or signs that marked the town's sundown status. He further notes that hundreds of cities across America have been sundown towns at some point in their history. Additionally, Loewen writes that sundown status meant more than just that African Americans were unable to live in these towns. Any black people who entered or were found in sundown towns after sunset were subject to harassment, threats, and violence, including lynching. The Supreme Court case Brown v. Board of Education ruled segregation of schools unconstitutional in 1954. Loewen argues that the case caused some municipalities in the South to become sundown towns: Missouri, Tennessee, and Kentucky saw drastic drops in African-American populations living in those states following the decision. Function Ethnic exclusions African Americans were not the only minority group not allowed to live in white towns. One example, according to Loewen, is that in 1870, Chinese people made up one-third of Idaho's population. Following a wave of violence and an 1886 anti-Chinese convention in Boise, almost none remained by 1910. The towns of Minden, Nevada, and Gardnerville, Nevada, had an ordinance from 1917 to 1974 that required Native Americans to leave the towns by 6:30 p.m. each day. A whistle, later a siren, was sounded at 6 p.m. daily alerting Native Americans to leave by sundown. In 2021, the state of Nevada passed a law prohibiting the appropriation of Native American imagery by the mascots of schools, and the sounding of sirens that were once associated with Sundown ordinances. Despite this law, Minden has continued to play its siren, claiming it as being a nightly tribute to first responders. In Nevada, the ban was expanded to include Japanese Americans. Two examples of the numerous road signs documented during the first half of the 20th century include: In Colorado: "No Mexicans After Night". In Connecticut: "Whites Only Within City Limits After Dark". In Maria Marulanda's 2011 article in the Fordham Law Review titled "Preemption, Patchwork Immigration Laws, and the Potential for Brown Sundown Towns", Marulanda outlines the possibility for non-blacks to be excluded from towns in the United States. Marulanda