Black housing was often segregated in the North. There was competition for jobs and housing as blacks entered cities which were also the destination of millions of immigrants from eastern and southern Europe. As more blacks moved north, they encountered racism where they had to battle over territory, often against ethnic Irish, who were defending their power base. In some regions, blacks could not serve on juries. Blackface shows, in which whites dressed as blacks portrayed African Americans as ignorant clowns, were popular in North and South. The Supreme Court reflected conservative tendencies and did not overrule Southern constitutional changes resulting in disfranchisement. In 1896, the Court ruled in "Plessy v. Ferguson" that "separate but equal" facilities for blacks were constitutional; the Court was made up almost entirely of Northerners. However, equal facilities were rarely provided, as there was no state or federal legislation requiring them. It would not be until 58 years later, with Brown v. Board of Education (1954), that the Court recognized its 1896 error.