Answer: During Reconstruction freed slaves began to leave the South. One such group, originally from Kentucky, established the community of Nicodemus in 1877 in Graham County on the high, arid plains of northwestern Kansas. That African Americans became American citizens was arguably the signal development during Reconstruction. Only a decade earlier the Supreme Court had ruled in the Dred Scott decision in 1858 that people of African descent imported into the United States and held as slaves, or their descendants—whether or not they were slaves—could never be citizens of the United States. When, during the Civil War, slaves began to flee to Union lines in growing numbers and after the Emancipation Proclamation, it became clear that “facts on the ground” would overtake the Dred Scott decision. However, any resolution of the status of former slaves had to be resolved within the context of American federalism, because until that time citizenship was defined and protected by state law. Therefore, the resolution of the citizenship status of blacks was contingent on the status of the former Confederate states and their relationship with the nation at large.