The Fourteenth Amendment to the United States Constitution was proposed by Congress on June 13, 1866. By July 9, 1868, it had received ratifications by the legislatures of the required number of states in order to officially become the Fourteenth Amendment. On July 20, 1868, Secretary of State William Seward certified that it had been ratified and added to the federal Constitution. The amendment addresses citizenship rights and equal protection of the laws. It was proposed in response to issues related to treatment of freedmen following the war. The amendment was bitterly opposed, particularly by Southern states, which were forced to ratify it in order for their delegations to be able to return to Congress. The Fourteenth Amendment, particularly its first section, is one of the most litigated parts of the Constitution. It formed the basis for landmark decisions such as "Roe v. Wade" (1973), regarding abortion, and "Bush v. Gore" (2000), regarding the 2000 presidential election.