Amendment as follows: Like Alexander Hamilton, Madison was concerned that enumerating various rights could "enlarge the powers delegated by the constitution". To attempt to solve this problem, Madison submitted this draft to Congress: This was an intermediate form of the Ninth Amendment that borrowed from the Virginia proposal, while foreshadowing the final version. The final text of the Ninth Amendment, like Madison's draft, speaks of other rights than those enumerated in the Constitution. The character of those other rights was indicated by Madison in his speech introducing the Bill of Rights (emphasis added): The First through Eighth Amendments address the means by which the federal government exercises its enumerated powers, while the Ninth Amendment addresses a "great residuum" of rights that have not been "thrown into the hands of the government", as Madison put it. The Ninth Amendment became part of the Constitution on December 15, 1791, upon ratification by three-fourths of the states. The final form of the amendment ratified by the states is as follows: Judicial interpretation The Ninth Amendment has generally been regarded by the courts as negating any expansion of governmental power on account of the enumeration of rights in the Constitution, but the Amendment has not been regarded as further limiting governmental power. The U.S. Supreme Court explained this, in U.S. Public Workers v. Mitchell : "If granted power is found, necessarily the objection of invasion of those rights, reserved by the Ninth and Tenth Amendments, must fail." The Supreme Court held in Barron v. Baltimore (1833) that the Bill of Rights was enforceable by the federal courts only against the federal government, not against the states. Thus, the Ninth Amendment originally applied only to the federal government, which is a government of enumerated powers. Some jurists have asserted that the Ninth Amendment is relevant to the interpretation of the Fourteenth Amendment. Justice Arthur Goldberg (joined by Chief Justice Earl Warren and Justice William Brennan) expressed this view in a concurring opinion in the case of Griswold v. Connecticut (1965): In support of his interpretation of the Ninth, Goldberg quoted from Madison's speech in the House of Representatives as well as from Alexander Hamilton's Federalist Paper No. 84: But the two Justices who dissented in Griswold replied that Goldberg was mistaken to invoke the Ninth as authority. Hugo Black's dissent said: And Potter Stewart's dissent said: Since Griswold, some judges have tried to use the