Some have suggested that the Privileges or Immunities Clause would be a more appropriate textual basis than the due process clause for incorporation of the Bill of Rights. It is often said that the "Slaughter-House Cases" "gutted the privileges or immunities clause" and thus prevented its use for applying the Bill of Rights against the states. In his dissent to "Adamson v. California", however, Justice Hugo Black pointed out that the "Slaughter-House Cases" did not directly involve any right enumerated in the Constitution: