White next outlined the history of the "privileges and immunities" clause of Article IV, Sec. 2, of the Constitution. In the space of less than one sentence, White came to the landmark conclusion that only the states had enforcement authority over the "privileges and immunities" mentioned in Article IV. The "privileges and immunity" clause, White wrote, was a linear descendant of a similar if limited clause in the Articles of Confederation. "[The] Constitution plainly intended to preserve and enforce the limitation..." White reasoned, and thus "the continued possession by the States of the reserved power to deal with free residence, ingress and egress, cannot be denied."Wheeler, 254 U.S. at 282, citing .
