Supreme Court Associate Justice Black was one of the most influential justices in the twentieth century, but his legacy has been called into question by his one-time membership in the Ku Klux Klan. He advanced the judicial doctrine of “incorporation,” by which the life, liberty, and property protections of the Fourteenth Amendment were found to extend to rights enumerated in the Bill of Rights. In this manner, rights which before had applied only in the federal sphere now also applied in state and local context. The religion clauses were “incorporated” in the 1940s.