Two important cases, Runyon v. McCrary and Patterson v. McLean Credit Union, raise the issues of whether the framers of the Statute intended it to protect civil rights not only from discriminatory State action but also from private discrimination. The article argues that the legislative and enforcement history of the statute show that the framers did not intend to limit its interpretations to State action. Instead, they did not distinguish between State and private action but intended that the Civil Rights Act of 1866 confer jurisdiction on the Federal courts to give direct relief to those who were victims of civil rights violations. 146 footnotes.