This was the Supreme Court's first voting rights case under the Fifteenth Amendment and the Enforcement Act of 1870. A Kentucky electoral official had refused to register an African‐American's vote in a municipal election and was indicted under two sections of the 1870 act: section 2 required that administrative preliminaries to elections be conducted without regard to race, color, or previous condition of servitude; section 3 forbade wrongful refusal to register votes where