In 1874, after the war, Congress passed the Poland Act, which transferred jurisdiction over Morrill Act cases to federal prosecutors and courts, which were not controlled by Mormons. In addition, the Morrill Act was upheld in 1878 by the United States Supreme Court in the case of "Reynolds v. United States". After "Reynolds", Congress became even more aggressive against polygamy, and passed the Edmunds Act in 1882. The Edmunds Act prohibited not just bigamy, which remained a felony, but also bigamous cohabitation, which was prosecuted as a misdemeanor, and did not require proof an actual marriage ceremony had taken place. The Act also vacated the Utah territorial government, created an independent committee to oversee elections to prevent Mormon influence, and disenfranchised any former or present polygamist. Further, the law allowed the government to deny civil rights to polygamists without a trial.