Application.
In the year of the 150th anniversary of the Fifteenth Amendment Columbia University history professor and historian Eric Foner said about the Fifteenth Amendment as well as its history during the Reconstruction era and Post-Reconstruction era:
It's a remarkable accomplishment given that slavery was such a dominant institution before the Civil War. But the history of the 15th Amendment also shows rights can never be taken for granted: Things can be achieved and things can be taken away.
Reconstruction.
African Americans called the amendment the nation's "second birth" and a "greater revolution than that of 1776" according to historian Eric Foner in his book The Second Founding: How the Civil War and Reconstruction Remade the Constitution. The first black person known to vote after the amendment's adoption was Thomas Mundy Peterson, who cast his ballot on March 31, 1870, in a Perth Amboy, New Jersey referendum election adopting a revised city charter. African Americans—many of them newly freed slaves—put their newfound freedom to use, voting in scores of black candidates. During Reconstruction, 16 black men served in Congress and 2,000 black men served in elected local, state and federal positions according to Columbia University history professor Eric Foner.
In United States v Reese (1876), the first U.S. Supreme Court decision interpreting the Fifteenth Amendment, the Court interpreted the amendment narrowly, upholding ostensibly race-neutral limitations on suffrage including poll taxes, literacy tests, and a grandfather clause that exempted citizens from other voting requirements if their grandfathers had been registered voters. The Court also stated that the amendment does not confer the right of suffrage, but it invests citizens of the United States with the right of exemption from discrimination in the exercise of the elective franchise on account of their race, color, or previous condition of servitude, and empowers Congress to enforce that right by "appropriate legislation". The Court wrote:
The Fifteenth Amendment does not confer the right of suffrage upon anyone. It prevents the States, or the United States, however, from giving preference, in this particular, to one citizen of the United States over another on account of race, color, or previous condition of servitude. Before its adoption, this could be done. It was as much within the power of a State to exclude citizens of the United States from voting on account of race, & color, as it was on account of age, property, or education. Now it is not. If citizens of one race having certain qualifications are permitted by law to vote, those of another having the same qualifications must be. Previous to this amendment, there was no constitutional guaranty against this discrimination: now there is. It follows that the amendment has invested the citizens of the United States with a new constitutional right which is within the protecting power of Congress. That right is an exemption from discrimination in the exercise of the elective franchise on account of race, color, or previous condition of servitude. Under the express provisions of the second section of the amendment, Congress may enforce it by "appropriate legislation".
