Noah Swayne, the Supreme Court justice from the United States v. Rhodes case, and Joseph P. Bradley, another Supreme Court justice, dissented, maintaining that in order to have meaningful effects, the Thirteenth Amendment would have to address systemic racial oppression.
In conclusion, the Supreme Court ruled that victims were not entitled to protection from the state law because the word "affected" in the law did not apply to victims of crimes who are not defendants in a case.