"Runyon"'s holding was severely limited by "Patterson v. McLean Credit Union", which narrowly construed Section 1981 as not applying to any discrimination occurring "after" the making of a contract, such as racial harassment on the job (although the "Patterson" majority expressly claimed that they were "not" overruling "Runyon").In turn, "Patterson" was legislatively overruled by the Civil Rights Act of 1991.