In 1954, the Supreme Court decided "Brown v. Board of Education", which ruled that segregated schools violate the Constitution. Many people in southern states strongly opposed the "Brown" decision. James J. Kilpatrick, an editor of the "Richmond News Leader", wrote a series of editorials urging "massive resistance" to integration of the schools. Kilpatrick, relying on the Virginia Resolution, revived the idea of interposition by the states as a constitutional basis for resisting federal government action. A number of southern states, including Arkansas, Louisiana, Virginia, and Florida, subsequently passed interposition and nullification laws in an effort to prevent integration of their schools.