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===Origins of the Legal Battle===
Almost immediately, Black activists began to battle for the restoration of their civil rights. In Defining
Freedom, Susan Carle argues that this began in the 1880s with groups like the Afro-American League, under the leadership of Howard Law School graduate, T. Thomas Fortune, pressuring the state through legal test cases. The strategy was to utilize incidents of racial discrimination as “tests” to bring to the courts to get them to rule on the legality of segregation. In the 1890s, another organization, the Afro-American Council continued this strategy. However, with the Plessy v. Ferguson decision of 1896, it seemed things would get a bit more difficult.
===Early Twentieth Century Movements===