The decision was finally reversed by the Civil Rights Act of 1865.[66] In what is sometimes considered mere obiter dictum the Court went on to hold that Congress had no authority to prohibit slavery in federal territories because enslaved people are personal property and the Fifth Amendment to the Constitution protects property owners against deprivation of their property without due process of law. Although the Supreme Court has never explicitly overruled the Dred Scott case, the Court stated in the Slaughter-House Cases that at least one part of it had already been overruled by the Fourteenth Amendment in 1868, which begins by stating, "All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside."[67]