Initially the supreme court stayed within a limited scope of the amendment... The nineteenth-century Supreme Court decisions under the Fourteenth Amendment followed the limited scope and intentions of its authors. The Court declared that it was only “state action of a particular character that is prohibited”; “Individual invasion of individual rights is not the subject matter of the amendment.” Public accommodation laws were therefore held invalid. Even lynchings of prisoners in state custody were ruled beyond the scope of the Amendment. Sowell, Thomas. Knowledge And Decisions (p. 247).