The prospect of greater state influence in matters of race worried numerous advocates of civil equality, including Supreme Court Justice John Harlan, who wrote in his "Plessy" dissent, "we shall enter upon an era of constitutional law, when the rights of freedom and American citizenship cannot receive from the nation that efficient protection which heretofore was unhesitatingly accorded to slavery and the rights of the master." Harlan's concerns about the encroachment on the 14th Amendment would prove well-founded; states proceeded to institute segregation-based laws that became known as the Jim Crow system. In addition, from 1890 to 1908, Southern states passed new or amended constitutions including provisions that effectively disenfranchised blacks and thousands of poor whites.