Following states such as New York, Connecticut, Vermont and Ohio, Rhode Island also passes a personal liberty law.

The first lawsuit challenging separate but equal laws is fought in Boston. The case,   Robert v. Boston is filed by Benjamin Roberts files a school desegregation lawsuit for his daughter, Sarah, who was unable to register for public school in Boston. The lawsuit was unsuccessful and was used to support the separate but equal argument in the Plessy v. Ferguson case of 1896.