 States also used grandfather clauses to enable illiterate whites who could not pass a literacy test to vote.It allowed a man to vote if his grandfather or father had voted prior to January 1, 1867; at that time, most African Americans had been slaves, while free people of color, even if property owners, and freedmen were ineligible to vote until 1870.Justice Benjamin Curtis' dissent in "Dred Scott v. Sandford, 60 U.S. 393 (1857)" had noted that free people of color in numerous states had the right to vote at the time of the Articles of Confederation (as part of the argument about whether people of African descent could be citizens of the new United States)