The First Amendment, indeed the whole Bill of Rights, talks only about protecting American rights from action by the federal government. While some states included freedom of religion in their state constitutions, state governments did not have to obey the First Amendment regarding freedom of religion. After the American Civil War (1861-1865), however, the states adopted the Fourteenth Amendment to the U.S. Constitution in 1868. The Due Process Clause in the Fourteenth Amendment says, "No State shall ... deprive any person of life, liberty, or property, without due process of law." Interpreting the "liberty" portion of the Due Process Clause, the U.S. Supreme Court has decided that state governments also must obey most of the Bill of Rights, including the First Amendment's guarantee of freedom of religion.