 Southern states proceeded to adopt literacy requirements and other tests of a voter’s knowledge, poll taxes, and a variety of other measures that, applied in a discriminatory manner by local registrars and combined with terrorist violence and economic coercion, succeeded in disenfranchising the vast majority of blacks in the region. And despite the open defiance of the 15th Amendment, in Giles v. Harris (1903), the Supreme Court declared that the federal judiciary was not the place to go for blacks who sought the abrogation of the system of disenfranchisement. Justice Holmes wrote for the court that “relief from a great political wrong, if done, as alleged, by the people of a state and the state itself must be given by them or by the legislative and political department of the government of the United States” (488). But Holmes and every other minimally-informed American at the time knew full well that there was no realistic possibility that Southern states or Congress would voluntarily act to protect the voting rights of blacks. 