President Andrew Jackson’s Proclamation of 1832 rejected the South Carolina Ordinance of Nullification and rejected secession as a constitutional right. South Carolina’s legislature passed a Counter-Proclamation that citizens of states owed their chief allegiance to their sovereign state and not the national government and were duty-bound to maintain sovereign states’ rights. Increasingly, Americans failed to find common ground in their understanding of constitutional history. Enforcement of the Constitution’s Fugitive Slave Clause generated important Supreme Court cases such as Prigg v. Pennsylvania (1842) and Ableman v. Booth (1859) as Southern states sought to enforce the Slave Clause through federal legislation such as the Fugitive Slave Act of 1850. Northern states responded by passing personal liberty laws to resist the enforcement of federal laws that would extend the authority of enslavers beyond the South. Southern states considered these personal liberty laws a nullification of federal law and as intended to eradicate slavery. The Kansas–Nebraska Act of 1854 and the election of Abraham Lincoln in 1860 moved the nation beyond interposition towards secession and civil war.