Wolford v. Lopez · ¶82

We could stop there, but there is another reason for rejecting Hawaii’s reliance on this statute. It was adopted by the Louisiana Legislature between the end of the Civil War and the beginning of Reconstruction. When the war ended, the legislatures in defeated Confederate States quickly enacted so-called Black Codes that aimed to perpetuate the subjugation of blacks.The statute Hawaii cites was part of Louisiana’s Black Code, and it provided a tool for disarming blacks and thus leaving them defenseless against attacks. See 125 F. 4th, at 1239 (VanDyke, J., dissenting from denial of reh’g en banc).

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