The "Patterson" case had attracted much criticism since it appeared to leave employees who had been victimized by racial harassment on the job with no effective remedies, as they could not prove a violation of Section 1981 and could rarely show any wage losses that they could recover under Title VII. In addition, the Court's narrow reading of the phrase "make or enforce contracts" eliminated any liability under Section 1981 for lost promotions and most other personnel decisions that did not constitute a refusal and that was the end to hire or a discharge on the basis of race or color.