 A second wave of violence began, resulting in over 1,000 deaths, usually black or Republican.The Supreme Court ruled in 1876 in "United States v. Cruikshank", arising from trials related to the Colfax Massacre, that protections of the Fourteenth Amendment, which the Enforcement Acts were intended to support, did not apply to the actions of individuals, but only to the actions of state governments.They recommended that persons seek relief from state courts, which had not been supportive of freedmen's rights.