Congress enacted the Civil Rights Act of 1875. It guaranteed African Americans equal treatment in public accommodations, public transportation, and to prevent being excluded from jury duty. The bill was passed by the 43rd United States Congress and signed into law by President Ulysses S. Grant on March 1, 1875. Several years later, the Supreme Court ruled in "Civil Rights Cases" (1883) that sections of the act were unconstitutional. The Court's reasoning was the Fourteenth Amendment prohibited discrimination by states not by individuals. As a result Congress could not protect against individual cases of discrimination.