 Some constitutional scholars argue that any special "right" of Texas to create new states was ended by the secession of Texas in 1861, to join the Confederacy, and its subsequent, formal, readmission to the United States of America in 1865.Complicating this argument is an 1869 United States Supreme Court ruling, Texas v. White, holding that Texas remained part of the United States even during the Civil War.The division of the state of Texas was frequently proposed in the early decades of Texan statehood, particularly in the decades immediately prior to and following the American Civil War.