 In the decades following the Civil War, the U.S. Supreme Court ruled that, as a matter of constitutional law, political rights were not among the rights held by all adult citizens and that Congress had no authority to prohibit racial discrimination in access to the goods and services of private firms that catered to the public. In Minor v. Happersett, the Court invoked the civil-political distinction in holding that, even though women were undoubtedly citizens, “the Constitution, when it conferred citizenship, did not necessarily confer the right of suffrage” (1874: 177). And in the Civil Rights Cases, the Court struck down the Civil Rights Act of 1875, writing that the Constitution did not confer upon Congress the power “to adjust what may be called the social rights of men and races in the community, but only to declare and vindicate those fundamental rights which appertain to the essence of citizenship” (1883: 22).