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account of race. 23 Similarly, a Columbia Law Review article"admitted"that Giles and a follow-up case, Giles v. Teasley, 4"have made it quite difficult to bring the question squarely before the Supreme Court [of whether the disfranchising constitutions violated the Fifteenth Amendment].. None of these articles suggested that Mills offered any comparable obstacle If any contemporary actor of the time saw Giles as "basically concerned with procedural issues of no lasting consequence, I have not run across them. Nor does professor Heckman offer any such evidence from a single figure of the period; Professor Heckman focuses only on the formal texts of the opinion, rather than on the political and social context in which those decisions took on meaning To black activists seeking to stave off the elimination of black political participation, Giles must have been devastating. In many states, federal court litigation had been regarded for several years as the last, best chance to defeat disfranchisement-especially within the black community. This was because whites who also resisted disfranchisement often encouraged blacks to stay out of the political phase of the struggle over disfranchisement; the fear was that black participation would countermobilize more aggressive white support. In North Carolina, for example, Republican Party leaders, though fighting disfranchisement, dissuaded black leaders from mobilizing opposition during the 1900 campaign for popular approval of the constitutional Julien C monnet, The Latest Phase of Negro Disfranchisement, 26 Harv. L Rev. 42 53,54(1912-13 24193U.146(1904) See also william C. Coleman The fifteenth amendment 10 Colum. L. Rev. 416.448 n.73(1910). The quotation goes on to say: but it is thoroughly believed that court.. will, if necessary, make every endeavor to meet the question squarely, even to the extent of modifying or over-ruling a former decision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