It was not until the 14ᵗʰ amendment was adopted that there became a way to apply the Bill of Rights to the actions of states.

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The 14th amendment, ratified in 1868, includes the Due Process and Equal Protection Clauses, which have been interpreted to apply certain provisions of the Bill of Rights to the states. Prior to this amendment, the Bill of Rights only applied to the federal government.

It Was Not Until the 14ᵗʰ Amendment Was Adopted That