On June 4, 1965, US President Lyndon B. Johnson delivered a commencement address at Howard University in Washington, DC, that applauded efforts by the federal government to address race discrimination. Despite these efforts, however, the president stressed that the job was far from being complete. Though President Johnson did not explicitly use the phrase "affirmative action" in the address, he articulated the general policy behind such programs: "Freedom is not enough. You do not take a person who, for years, has been hobbled by chains and liberate him, bring him up to the starting line of a race and then say, 'you are free to compete with all the others,' and still justly believe that you have been completely fair. Thus it is not enough to just open the gates of opportunity. All our citizens must have the ability to walk through those gates." According to President Johnson, achieving racial equality required remedying America's history of racial discrimination. Racial discrimination against African-Americans was prevalent in early American society. In the South, slave owners treated African-American slaves like property. When a white citizen killed or raped an African-American slave, the action was typically prosecuted under property laws, such as trespass. In the North, free or escaped African-Americans encountered violence from whites, and faced segregation in public places and skilled labor. Some whites, like the founders of the American Colonization Society, argued for emigrating free African-Americans to Africa because they considered African-Americans unfit for existence in American society. The US Supreme Court's 1857 Dred Scott decision reinforced legal racial discrimination. The Court held that African-Americans, whether free or enslaved, were ineligible to become US citizens. In writing for the majority, Chief Justice Roger Taney reinforced notions of racial discrimination by stating that African-Americans were distinctly separate and inferior to whites. According to Justice Taney, the founding fathers did not intend for African-Americans to receive the rights that come with US citizenship. The decision also prohibited Congress from banning slavery in newly acquired territories.