Tenth Amendment Our Bill of Rights began when James Madison, the primary author of the Constitution, proposed 20 amendments to the Bill of Rights and not the ten we know today. Madison sent these twenty bills of rights to the House and Senate and was left with twelve bills of rights. Madison himself brought up some of it. These amendments were then sent to the states for ratification. Virginia was the tenth of the fourteen states to pass 10 of 12 amendments. This two-thirds majority was necessary to make the Bill of Rights legal. On December 15, 1791, the Bill of Rights was finally ratified. The great supporters of the Tenth Amendment were Anti-Federalists. Anti-Federalists are those who oppose a strong central government. The Articles of Confederation were adopted by the Continental Congress on December 15, 1777. It created a weak central government while leaving most power to the states. Even though this was what the Anti-Federalists wanted, they knew they needed a change in government. The Articles of Confederation state in section two that "Each state retains its sovereignty, liberty, and independence, and every power, jurisdiction, and right, which is not expressly delegated by this Confederation to the United States, assembled in Congress." From here comes, with some modifications, the Tenth Amendment. Both the Tenth Amendment and the Articles of Confederation provide that unenumerated powers are reserved to the states. The reason why the Tenth Amendment was included is the fight waged by the Anti-Federalists. They demanded state and individual rights, so James Madison drafted the bill The Commerce Clause refers to Article 1, Section 8, Clause 3 of the United States Constitution, which gives Congress the power “to regulate commerce with the nations foreign countries, and between the various states, and with the Indian tribes. The Commerce Clause gives the government power over the states. This was established in the case of Gibbons v. Ogden in 1824. Gibbons and Ogden both operated their steamboats along the same route, on the Hudson River, which was between New Jersey and New York. Ogden obtained an injunction through a New York state court. This injunction concluded that Ogden had obtained exclusive rights from the state to operate that route. Gibbons had received permission from the federal government. The New York court sided with Ogden and ordered Gibbons to stop operating his steamships. Gibbons then took the case to the Supreme Court. John Marshall sided with Gibbons and said that New York's grant to Ogden violated the Federal Licensing Act of 1793 and was the first time the Commerce Clause was being interpreted. It was concluded that the government had the power to regulate this due to the Commerce Clause. The Commerce Clause has since expanded government power more than states would like