Report of 1800  The Report of 1800 was a resolution drafted by James Madison arguing for the sovereignty of the individual states under the United States Constitution and against the Alien and Sedition Acts. Adopted by the Virginia General Assembly in January 1800, the Report amends arguments from the 1798 Virginia Resolutions and attempts to resolve contemporary criticisms against the Resolutions. The Report was the last important explication of the Constitution produced before the 1817 Bonus Bill veto message by Madison, who has come to be regarded as the "Father of the Constitution." The arguments made in the Resolutions and the Report were later used frequently during the nullification crisis of 1832, when South Carolina declared federal tariffs to be unconstitutional and void within the state. Madison rejected the concept of nullification and the notion that his arguments supported such a practice. Whether Madison's theory of Republicanism really supported the nullification movement, and more broadly whether the ideas he expressed between 1798 and 1800 are consistent with his work before and after this period, are the main questions surrounding the Report in the modern literature. Madison, a member of the Democratic-Republican Party, was elected to the Democratic-Republican-dominated Virginia General Assembly from Orange County in 1799. A major item on his agenda was the defense of the General Assembly's 1798 Virginia Resolutions, of which Madison had been the draftsman. The Resolutions, usually discussed together with Thomas Jefferson's contemporaneous Kentucky Resolutions, were a response to various perceived outrages perpetrated by the Federalist-dominated national government. The most significant of these were the Alien and Sedition Acts, four laws that allowed the President to deport aliens at will, required a longer period of residence before aliens could become citizens, and made it a crime to publish malicious or defamatory material against the government or its officials. Democratic-Republicans were outraged by the legislation, and Madison and Jefferson drafted the highly critical Resolutions adopted in response by the Virginia and Kentucky state legislatures. The Virginia and Kentucky Resolutions had in the year since publication received highly critical replies from state legislatures. Seven states formally responded to Virginia and Kentucky by rejecting the Resolutions and three other states passed resolutions expressing disapproval, with the other four states taking no action. No other state endorsed the Resolutions. The reason for the criticism was that the General Assembly, led in the effort by state-sovereignty advocate John Taylor of Caroline, had put a state-sovereignty spin on the Virginia Resolutions of 1798 despite Madison's hopes. These replies contended that the Supreme Court of the United States had the ultimate responsibility for deciding whether federal laws were constitutional, and that the Alien and Sedition Acts were constitutional and necessary.