In Hodges v. United States (1906) the Court addressed a possible Thirteenth Amendment rationale for the Enforcement Acts, and found that the federal government did not have the authority to punish a group of men for interfering with black workers through whitecapping. Hodges v. United States would be overruled in Jones v. Alfred H. Mayer Co. some 50 years later, stating for the first time since Reconstruction that the federal government could criminalize racist acts by private actors.
in hodgeS v. unITed statEs (1906) the CourT AddrEssed a PoSSiBLe tHirteentH ameNdment rAtIonalE for the enforceMent acts, aND fouND tHAT the fEDEral goverNmEnt dId not Have tHE auTHoRitY TO puNisH a Group Of mEn For intErFerInG wiTH blaCk workers THRoUgh whiTecapping. HodGES v. UniteD stateS wOUlD Be oVERruLed In JonES v. AlfRed h. mayer cO. soMe 50 YeArs LatEr, staTing foR tHe first TIme SInCE reconsTRuCTIon that the federal gOverNmenT could crimInaLIZE racist acts BY privAte AcTORs.