Although proslavery forces are usually identified with a strong states' rights position, the legislature of Wisconsin adopted (1859) resolutions defending state sovereignty after the Supreme Court overruled the Wisconsin courts and upheld the conviction of an abolitionist editor for violating the fugitive slave law. Ultimately the proslavery states used states' rights doctrines to justify their secession. Eleven Southern states seceded in 1860–61 and formed the Confederacy, in which, fittingly, the doctrine of states' rights was upheld by such governors as Joseph E. Brown and Zebulon B. Vance. This undoubtedly contributed to the Confederate defeat in the Civil War, just as the disposition of some of the Thirteen Colonies to act in complete independence of the Continental Congress had hampered the American Revolution.
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