The framers of the first state constitutions established a system in which the representatives of the people, embodied in their legislatures, were to be supreme within governments. With only two partial exceptions, the early constitutions imposed no formal check on the power of legislatures to make law. But these representative bodies were not, for the most part, regarded as sovereign. Rather, most Americans believed that the sovereign people themselves would supervise the conduct of their representatives.1 Constitutional restrictions would be enforced against legislatures “politically” through a variety of forms of popular action, but most especially by means of the frequent (annual) elections almost all the first constitutions required for their lower houses. Legislatures would be held to constitutional standards as popular opinion interpreted those. Under this system, the people would be entirely free to enact (through their legislatures) the laws by which they wished to govern themselves. Whenever they came to believe that their legislators had overstepped constitutional bounds in passing a particular statute, they possessed the plenary power to replace them with representatives who would more faithfully adhere to constitutional standards, and repeal offending legislation.