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Although the 13th amendment permanently outlawed slavery in the United States and its territories, the Supreme Court had already set precedence, specifically with the Dred Scott case (see Dred Scott v. Sandford), determining that Negroes, whether free or slave could never be citizens of the United States. Since the Supreme Court makes rulings solely on Constitutional law, the 14th amendment was intended to essentially overturn this decision and assert the citizenship "all persons born or naturalized in the United States." It is different than the 15th amendment in that the 15th specifically guarantees the right to vote regardless of race,color, or previous condition of servitude. To understand why this was necessary, one only need remember that citizenship did not necessarily guarantee one's right to vote (technically, women conformed to the clause "all persons born or naturalized in the United States" articulated in the 14th amendment but did not have the national right to vote until 1920).

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