In 1875, two inspectors of a municipal election in Kentucky were indicted for refusing to receive and count the vote of a Negro. The Supreme Court[697] of the United States, to which the case came by reason of a division of opinion of the Circuit Court, held that the Fifteenth Amendment did not confer the right of suffrage, but rather invested citizens with the right of exemption from discrimination in the exercise of the elective franchise on account of their race, color, or previous condition of servitude. The fourth section of the Act of 1870, by its language, did not confine its operation to unlawful discrimination on account of race or color and was, therefore, unconstitutional. The “Enforcement Act” of 1870, like the Civil Rights Bill of 1875, failed in its desired effect because it was too far-reaching in its scope. Had the Act of 1870 been upheld, the Federal authorities would have taken complete control of all elections, State as well as Federal. The years between 1870 and 1890 are known for the actual race distinctions in suffrage. Between 1870 and 1877, the white people of the South were largely disfranchised, not because of their race, but because of their participation in the War. After 1877, the Negroes were largely disfranchised by unlawful methods adopted by the white people of the South. If this were a history of the actual race distinctions in suffrage, it would be necessary to consider at length the “tissue ballots,” the stuffing of ballot boxes, the intimidation of Negroes by the Ku Klux Klan and other bodies of white men, and other election devices and practices in the South at that time. But this study, as has been said before, is confined to the race distinctions _in_ the law, not those _in defiance of_ the law. Out of all the suffrage irregularities of the period very little suffrage law was evolved. Few judicial decisions and no statutes bearing directly on the relation of race to suffrage have been found.