; Whereas section 1 of the Civil Rights Act of 1866 was used to challenge the laws established by southern States to limit the rights and opportunities of newly freed slaves; Whereas under section 1977 of the Revised Statutes ( 42 U.S.C. 1981 ), as derived from section 16 of the Enforcement Act of 1870 (16 Stat. 140) and section 1 of the Civil Rights Act of 1866 (14 Stat. 27), African-American citizens are given the right to enforce contracts, give evidence in court, sue and be sued, and purchase, sell, and convey real and personal property; Whereas, in 1975, the Supreme Court found in Johnson v. Railway Express Agency, Inc., 421 U.S. 454 (1975), that section 16 of the Enforcement Act of 1870 (16 Stat. 140) allowed for private employers to be held accountable for discrimination within their ranks; Whereas section 1977 of the Revised Statutes ( 42 U.S.C. 1981 ) applies to all contracts, including those between employer and employee, and has become a vital tool for employment discrimination claimants; Whereas section 1977 of the Revised Statutes ( 42 U.S.C. 1981 ) stands as one of the only laws protecting against employers openly discriminating on the basis of race when contracting with other parties; Whereas it is well established that section 1977 of the Revised Statutes ( 42 U.S.C. 1981 ) has been invoked to challenge race discrimination in employment matters and has held bad actors accountable for contract discrimination; Whereas, in 1989, the Supreme Court narrowly interpreted section 1977 of the Revised Statutes ( 42 U.S.C. 1981 ) to only apply to contract formation in Patterson v. McLean Credit Union, 491 U.S. 164 (1989), finding that only certain points in a contractual engagement could be subject to the protections afforded in such section; Whereas the ruling in Patterson v. McLean Credit Union, 491 U.S. 164 (1989) functioned as a major setback in ensuring that all aspects of an employee or individual’s interaction with a business would be free of racial discrimination