According to Justice Bradley's opinion in the Cruikshank case, to federalize a common-law crime: "There must be a design to injure a person, or deprive him of his equal right of the protection of the laws, because of his race, color, or previous condition of servitude... otherwise it is a case exclusively within the jurisdiction of the state and its courts" (Naidoo, 2016).
add 3-4 sentences