It will be noticed that nearly all of the cases cited above are along the same line—intimidation of Negroes to keep them from voting. Several constitutional principles, however, relating to suffrage were evolved out of the cases decided during this period. In some of these cases a Negro was not a party at all. It was thought at first, for instance, that suffrage was a right of citizenship and that the Fourteenth Amendment entitled every citizen to vote. Consequently, a proceeding was started in the courts of Kentucky in 1874 to establish the right of a woman to vote. The case went up to the Supreme Court[707] of the United States which held that the Constitution of the United States does not confer the right of suffrage upon anyone. Next, it was thought that the Fifteenth Amendment conferred the right to vote upon Negroes, but the case of United States v. Reese settled this point by deciding that the Amendment did not confer upon Negroes the right to vote, but the right not to be discriminated in voting on account of race, color, or previous condition of servitude.[708] Despite the Fourteenth and Fifteenth Amendments, the principle remains that the individual States retain the right to prescribe the qualifications for voting so long as they do not discriminate against persons on account of race, color, or previous condition of servitude. SOUTHERN SUFFRAGE AMENDMENTS SINCE 1890 In 1890, a distinct departure was made in the development of the law of suffrage. For thirteen years, roughly speaking, the Negroes had been in a great measure disfranchised by the illegal means already referred to. According to the Constitutions and laws of the Southern States, the Negro had precisely the same right to vote as the white person. Yet he did not vote, or, if he voted, his ballot came to naught. The Southern white people, wearied of using underhand methods of eliminating the effect of Negro suffrage, turned to seek a method under the law to accomplish the same result. The Fifteenth Amendment seemed to offer an insuperable obstacle. The problem was how to evade this constitutional provision. Speaking of this difficulty, the Supreme Court of Mississippi[709] said: “Within the field of permissible action under the limitations proposed by the Federal Constitution, the Convention [the Constitutional Convention of Mississippi, 1890] swept the field of expedients to obstruct the exercise of suffrage by the Negro race. By reason of its previous condition of servitude and dependency, this race had acquired or accentuated certain peculiarities of habit, or temperament, and of character, which clearly distinguished it as a race from the whites. A patient, docile people; but careless, landless, migratory within certain limits, without forethought; and its criminal members given to furtive offences rather than the robust crimes of the whites. Restrained by the Federal Constitution from discriminating