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Giles's lawyer framed the issue in the broad test-case terms in which blacks who were active in the litigation, supported it, and were watching it, understood the stakes: a more high handed and flagrant case of the nullification of the fourteenth and fifteenth amendments to the Constitution of the United States and repudiation of their solemn guarantees to the negroes of America can never be presented to the courts of the country. Giles brief concluded in ways that could hardly have framed the confrontation more momentously: " And this court must know that the honor of this nation is bound to suffer in the estimation of the world if its solemn constitutional guarantees made to the negro shortly after the late civil war, when his conspicuous service in behalf of the Union was fresh in the minds of the American people, are allowed to go unenforced, and to become a dead letter in a well-established case like this. 9 To dispute that the stakes were high would be foolhardy, given that the new Alabama Constitution of 1901 contained, as later historians have remarked, the most elaborate suffrage requirements that have ever been in force in the United States. Moreover, Jackson Giles was hardly an idiosyncratic well-to-do plaintiff off on a solitary litigation lark. Giles, a janitor in the federal courthouse in Montgomery, Alabama, was president of an Alabama organization called the Colored Men's Suffrage Association. More work needs to be done on the history of this intriguing organization, bRief for Appellant in Giles v. Harris, No 493, at 4 (October Term, 1902) Id, at 16. Earlier, the brief had further framed the issue, not in the narrow procedural terms Professor Heckman sees, but in the broad terms that the case was obviously meant to raise To the negro, if the guarantees of the fourteenth and fifteenth amendments are stricken from under him, under the pretense of the want of jurisdiction in the courts of the United States to enforce them, he has only one other guarantee between him and actual slavery: that is the one contained in the thirteenth amendment. What reason would he have to hope for protection under that one, should the Southern states by similar methods undertake to deprive him of that rantee? "Id. at 7 10See the Canon at>    C+"4 @%" @E ."#% D " #-2" . *   *"     0   * !   ".*   .      0 .+ *  = 9    " *    *           * "*       0  5*     *   ?  1      "   * . 0   *+=               F  0 * +      *    " *  1 *  1  . *     +   * G:D " $  1  "  & C0  *  .  "  <  0.0 0  +    "*    " 00   "*    =9 <        *    *           *   ?  1    *      *         +.      *    * : C. *   0   *  +        *=9   * *  0        . *  *      0       * *           +0"0   * * + .  ? 0        " 0   *    "  .     0< .  :    *      00 * .  "+     0.  *  #%#    "   + "9   .  */*   + +.     ?  1  : 3  +"B C0     " 0< <         C"5     * * 3  "."0     .  8      3  1*  3 0    .       *   8 "
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