The birth and expansion of the American police can be traced to a host of contributing factors. The practice of enslavement and the control of minorities, however, were the leading causes of the formation of early policing. Slave patrols in the south, and northern constables were created to control the behaviors of minorities. These organizations served as the forerunner of modern American law enforcement. In the wake of Black Lives Matter, we are reminded of the long history of violent confrontations between African-American citizens and the police. The purpose of this research is to examine whether progress in law enforcement has been made following the Civil Rights Act of 1964. My hypothesis is that the current pervasive and disproportionate killing of African Americans indicates the Supreme Court’s inability to effectively remedy the injustices in American policing. I reviewed eleven sources to gather evidence to prove my hypothesis. Ultimately, The Civil Rights Act of 1964 was supposed to ban discrimination and extend all rights to African Americans. However, despite strides made during the Civil Rights Movement, police practices continue to mirror Jim Crow.