The twenties also saw the emergence of the black nationalist leader Marcus Garvey, a Jamaican possessed of a powerful, controversial message. Beyond urging black Americans to take pride in their African heritage, he also encouraged them to return to their ancestral African homeland. As head of the Universal Negro Improvement Association, Garvey attracted hundreds of thousands of supporters. In huge numbers they attended rallies, drawn to Garvey's assertive message, which rejected the notion that the black population would ever achieve equality in the United States. Garvey stands somewhat apart from the traditional race reform struggle for he advocated leaving the United States, rather than working to change it. If his program did not directly influence the trajectory of civil rights reform in the decades to come, his was the first genuine mass movement among the African American population.
Although the 1920s was not a decade notable for great achievements in race reform, the NAACP did work for change through legislative and judicial channels. Federal anti-lynching legislation was one of the association's key objectives, and civil rights reformers worked tirelessly to gain passage of a law to outlaw that gruesome crime. While such legislation never became law (it passed the House but not the Senate), many believed agitation for the bill contributed to a drop in the number of lynchings in this period. At the same time, the NAACP's energetic effort, which was led by a black man, James Weldon Johnson, represented the first time an African American leader had spearheaded the drive to pass civil rights legislation. It would not be the last.
But the dynamics of Congress prevented civil rights legislation from passing in these years. The key obstacle was the Senate. Under arcane and complicated senatorial rules, a small group of senators could block any legislation by filibustering. Essentially, that meant talking continuously, which in turn would prevent the Senate from voting before adjournment. A filibuster, or even the threat of a filibuster, could halt nascent legislation before it ever reached the full Senate. That, in effect, gave a minority of senators veto power over what the majority might want. In short, senatorial procedure was one factor that blocked civil rights reform during these decades.
Stymied on the legislative front, the NAACP did achieve some significant victories in court, the first of which was a 1923 ruling, Moore v. Dempsey, in which the Supreme Court ruled against mob influence in an Arkansas courtroom, by reversing a verdict that had wrongly sentenced a group of black man to death. In 1927, in Nixon v. Herndon, the Court struck down a Texas statute that excluded blacks from voting. While the NAACP realized there was still a long way to go on the franchise question, the decision represented a significant step along the road to full citizenship rights for black Americans.