new protections for black people afforded in the Fourteenth and Fifteenth Amendments. The enforcement acts, among other things, aimed to prohibit private individuals, such as the Ku Klux Klan, from conspiring to prevent black people from exercising their newly acquired civil rights. See Robert M. Goldman, A Free Ballot and a Fair Count: The Department of Justice and the Enforcement of Voting Rights in the South, 1877-1893 11-15 (New York: Garland Publishing, 1990). The Supreme Court repeatedly struck down the convictions of private individuals under the acts because the Fourteenth and Fifteenth Amendments from which the acts derived their authority regulated the conduct of state officials rather than private individuals. See United States v. Cruikshank, 92 U.S. 542, 23 L.Ed. 588 (1876) (<HOLDING>); Virginia v. Rives, 100 U.S. 339, 25 L.Ed. 676
holding that the second amendment fully applies to state and local regulation through the fourteenth amendment holding that the fourteenth amendment only applies to state action holding the sixth amendment right to a jury trial applies to the states through the fourteenth amendment holding that while the fourteenth amendment is directed against state action and not private action the state action requirement is met in a civil action where state law is applied whether by statute or common law holding that the fourteenth amendment protects property interests however only from a deprivation by state action