After several years of comparatively weak government under the Articles of Confederation, a Constitutional Convention in Philadelphia proposed a new constitution on September 17, 1787, featuring a stronger chief executive and other changes. George Mason, a Constitutional Convention delegate and the drafter of Virginia's Declaration of Rights, proposed that a bill of rights listing and guaranteeing civil liberties be included. Other delegates including future Bill of Rights drafter James Madison disagreed, arguing that existing state guarantees of civil liberties were sufficient and that any attempt to enumerate individual rights risked the implication that other, unnamed rights were unprotected. After a brief debate, Mason's proposal was defeated by a unanimous vote of the state delegations. For the constitution to be ratified, however, nine of the thirteen states were required to approve it in state conventions. Opposition to ratification ("Anti-Federalism") was partly based on the Constitution's lack of adequate guarantees for civil liberties. The Third Amendment has been invoked in a few instances as helping establish an implicit right to privacy in the Constitution. Justice William O. Douglas used the amendment along with others in the Bill of Rights as a partial basis for the majority decision in Griswold v. Connecticut (1965), which cited the Third Amendment as implying a belief that an individual's home should be free from agents of the state.
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