Despite this reluctance, after the Supreme Court's holding in the 1886 case of Wabash, St. Louis & Pacific Railway Co. v. Illinois severely limited the power of states to regulate interstate commerce, Cleveland assented to legislation providing for federal oversight of railroads. He was unwilling to use federal power to enforce the Fifteenth Amendment, which guaranteed voting rights to African-Americans. Though Cleveland appointed no black Americans to patronage jobs, he allowed Frederick Douglass to continue in his post as recorder of deeds in Washington, D.C. and appointed another black man to replace Douglass upon his resignation. He was unwilling to use federal power to enforce the Fifteenth Amendment, which guaranteed voting rights to African-Americans. Though Cleveland appointed no black Americans to patronage jobs, he allowed Frederick Douglass to continue in his post as recorder of deeds in Washington, D.C. and appointed another black man to replace Douglass upon his resignation. During his first term, Cleveland successfully nominated two justices to the Supreme Court of the United States. After Associate Justice William Burnham Woods died, Cleveland nominated Interior Secretary Lucius Q.C.