James v. Bowman 190 U.S. 127 (1903)
JAMES v. BOWMAN 190 U.S. 127 (1903)
A provision of the force acts, passed to protect fifteenth amendment guarantees, forbade bribery or intimidation to prevent the exercise of voting rights. Bowman, a private citizen, was indicted for preventing several blacks from voting in a Kentucky congressional election. Justice david brewer for a 6–2 Supreme Court, relying mainly on united states v. reese (1876), declared that the amendment applied to abridgments of the right to vote by the federal government or by a state on account of race; it did not reach private actions. A congressional measure purporting to punish "purely individual action," said Brewer, could not be sustained as an enforcement of the Fifteenth Amendment's prohibition against state action abridging the right to vote on account of race. Further, the statute was not limited to racial discrimination denying the right to vote. Congress had not relied on its power under Article I to regulate federal elections.