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===Early Twentieth Century Movements===
''Plessy'' might be understood amid the strategies of Booker T. Washington and the Tuskegee Machine. In his famous speech a year before the legal case, known as the “Atlanta Compromise,” Washington argued that social agitation for rights should be pushed to the side in favor of separate development. It immediately allowed him access to philanthropic funds and , gained the purchase of many Southern leaders and Tuskegee University became a model for Black institutions in the South. But some Black leaders retorted that the question of rights should not be subordinated to separate development of the races and that rights were required to make that development happen.
[[File:Niagara.jpg|thumb|The Niagara Movement]]
Those who believed that Washington’s program was flawed continued to organize using the model of the test case. Many of the lawyers in the Black community joined their work to formations like the Afro-American Council and won many important victories for desegregation of public accommodations throughout the country. This strategy was followed by the Niagara Movement, which emerged to oppose the political tactic of the Tuskegee Machine in 1905. Their “Declaration of Principles” essentially affirmed their alignment with civil rights struggles of the past and foreshadowed the future.
