In 70 BC, Cicero refers to this killing in connection with Ceres' laws and cults. Spaeth believed that he was killed because:  Rather than attempting to atone for the murder, the Senate used a mission to Ceres' temple at Henna (in Sicily) to justify his execution. The agrarian reforms were only partially implemented by the commission; yet Gracchi colonies were set up in both Italy and Carthage. About nine years later Tiberius's younger brother, Gaius, passed more radical reforms. In addition to settling the poor in colonies on land conquered by Rome, he passed the "lex frumentaria", which gave the poor the right to buy grain at subsidized prices. In the past, the senate eliminated political rivals either by establishing special judicial commissions or by passing a "senatus consultum ultimum" ("ultimate decree of the senate"). Both devices allowed the senate to bypass the ordinary due process rights that all citizens had. Some of Gaius' followers caused the death of a man, many historians contend they were attacked and were acting in self-defense. In any case, the death was used by Gaius Gracchus's political rival, Lucius Opimius, to suspend the constitution again with another "senatus consultum ultimum". Gaius fled, but he was also probably murdered by the oligarchs. According to one ancient source, Gaius was not killed directly by them, but ordered his slave Philocrates to do the deed in a murder-suicide. The next major reformer of the time was Gaius Marius, who like the Gracchi, was a populist. Unlike them, he was also a general. He abolished the property requirement for becoming a soldier during the Jugurthine War, when the Roman army was very low on manpower and had difficulty maintaining the conflict. The poor enlisted in large numbers. This opening of the Army's ranks to the "capite censii" enfranchised the plebs, thus creating an "esprit de corps" in the enlarged army. Some elites complained that the army now became unruly due to the commoners in its ranks, but this is without good cause: Marius employed his soldiers to defeat an invasion by the Germanic Cimbri and Teutons. His political influence and military leadership allowed him to obtain six terms as consul in 107, and 103 to 99 BC, an unprecedented honour. However, on 10 December 100 BC the senate declared another "senatus consultum ultimum", this time in order to bring down Lucius Appuleius Saturninus, a radical tribune in the mould of the Gracchi who had been inciting violence in Rome on behalf of Marius' interests.