The Total Force Policy, 1973 Requires all active and reserve military organizations be treated as a single force. The Montgomery Amendment to the National Defense Authorization Act for Fiscal Year 1987 provides that a governor cannot withhold consent with regard to active duty outside the United States because of any objection to the location, purpose, type, or schedule of such duty. This law was challenged and upheld by the Supreme Court of the United States in 1990 in Perpich v. Department of Defense.[58] The John Warner Defense Authorization Act of 2007 Pub.L. 109–364 (text) (pdf) Federal law was changed in section 1076 so that the Governor of a state is no longer the sole commander in chief of their state's National Guard during emergencies within the state.