 Complete the following phrase:  Browns most notable action in the House was a speech he made on February 4, 1875, in response to Massachusetts Representative Benjamin F. Butlers call to pass the Civil Rights Act of 1875. Referring to comments Butler had made the previous day about lawlessness against African-Americans in the South, Brown claimed that unjust charges had been made against Southerners by an individual who is outlawed in his own home by respectable society, whose name is synonymous with falsehood, who is the champion, and has been on all occasions, of fraud; who is the apologist of thieves, who is such a prodigy of vice and meanness that to describe him would sicken the imagination and exhaust invective. Brown continued by referencing notorious Scottish murderer 