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Facilities and services such as housing, healthcare, education, employment, and transportation have been systematically separated in the United States based on racial categorizations. Segregation was the legally or socially enforced separation of African Americans from whites, as well as the separation of other ethnic minorities from majority and mainstream communities. While mainly referring to the physical separation and provision of separate facilities, it can also refer to other manifestations such as prohibitions against interracial marriage, and the separation of roles within an institution. The U.S. Armed Forces were formally segregated until 1948, as black units were separated from white units but were still typically led by white officers. In the 1857 Dred Scott case, the U.S. Supreme Court found that Black people were not and never could be U.S. citizens and that the U.S. Constitution and civil rights were not applicable to them. Congress passed the Civil Rights Act of 1875, but it was overturned by the U.S. Supreme Court in 1883 in the Civil Rights Cases. The U.S. Supreme Court upheld the constitutionality of segregation in Plessy v. Ferguson (1896), so long as "separate but equal" facilities were provided, a requirement that was rarely met. The doctrine's applicability to public schools was unanimously overturned in Brown v. Board of Education (1954). In the following years the court further ruled against racial segregation in several landmark cases including Heart of Atlanta Motel, Inc. v. United States (1964), which helped bring an end to the Jim Crow laws. Segregation was enforced across the U.S. for much of its history. Racial segregation follows two forms. De jure segregation mandated the separation of races by law, and was the form imposed by slave codes before the Civil War and by Black Codes and Jim Crow laws following the war. De jure segregation was outlawed by the Civil Rights Act of 1964, the Voting Rights Act of 1965, and the Fair Housing Act of 1968. De facto segregation, or segregation "in fact", is that which exists without sanction of the law. De facto segregation continues today in such closely related areas as residential segregation and school segregation because of both contemporary behavior and the historical legacy of de jure segregation.