“Thus, there was virtually no federal protection against employment discrimination in 1964. This was an appalling state of affairs considering that almost a hundred years earlier a Congress intimately familiar with slavery had declared that the lack of freedom to contract employment was a badge and incident of slavery. [See e.g., Johnson v. Railway Express Co., 421 U.S. 454 (1975)] The void which existed, and the hope that it soon would be filled, accounted for the anticipation — and dread — of the possible enactment of a fair employment title in the 1964 civil rights bill.”

Source: Linda S. Greene. Twenty Years Of Civil Rights: How Firm A Foundation? 37 Rutgers L. Rev. 707,720-721. 1984-1985. 


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