By the second section of the Fifteenth Amendment Congress is given power to enact, laws necessary for the enforcement of the prohibition expressed in the first section.

The federal authority thus granted, it is to be observed, has reference to all elections whether state or federal. In this respect it is thus much broader than that given in Section IV of Article I. In other respects, however, the power granted is much narrower, for it authorizes federal intervention only in cases where the right to vote has been denied or abridged on account of race, color, or previous condition of servitude. Thus in United States v. Reese29 an act of Congress which made it a crime to hinder, delay or restrict any citizen from doing any act to qualify him to vote or from voting at any election, was held void because its operation was not confined to cases in which the interference was on account of race, color, or previous condition of servitude.

$500 nor more than $5,000, or by imprisonment, with or without hard labor, not less than six months nor more than six years, or by both such fine and imprisonment."

29 92 U. S. 214; 23 L. ed. 563.

In James v. Bowman30 it was finally determined by the Supreme Court that the prohibition of the Fifteenth Amendment applied not to private but only to state action. Therefore- the court held void an act of Congress which provided for the punishment of individuals who by threats, bribery or otherwise should prevent or intimidate others from exercising the right of suffrage as guaranteed by the Fifteenth Amendment.

After reviewing the manner in which the prohibitions of the Fifteenth Amendment had, by judicial construction, been held to relate to state action only, and the legislative power of Congress under the enforcement clause of that Amendment limited to the enactment of laws providing remedies against unconstitutional state action, the cour't in its opinion, say: "These authorities show that a statute [of Congress] which purports to punish purely individual action cannot be sustained as an appropriate exercise of the power conferred by the Fifteenth Amendment upon Congress to prevent action by the State through some one or more of its official representatives." 31