On April 12, 1865, the American Civil War officially came to end when the Union Army accepted the unconditional surrender of the Confederacy on the steps of a courthouse in Appomattox, VA. The Union Army, led by two hundred thousand black soldiers, had destroyed the institution of slavery; as a result of their victory, black people were now to be no longer property but citizens of the United States.

The Civil Rights Act of 1866, the first declaration of civil rights in the United States, stated that

citizens of every race and color, without regard to any previous condition of slavery or involuntary servitude, shall have the same right, in every State and Territory in the United States . . . to full and equal benefit of all laws and proceedings for the security of person and property, as is enjoyed by white citizens.