other right (this concern eventually led to the Ninth and Tenth Amendments). After a brief debate, Mason's proposal was defeated by a unanimous vote of the state delegations. In the final days of the convention, North Carolina delegate Hugh Williamson proposed a guarantee of trial by jury in federal civil cases, but a motion to add this guarantee was also defeated. However, adoption of the Constitution required that nine of the thirteen states ratify it in state conventions. Opposition to ratification ("Anti-Federalism") was partly based on the Constitution's lack of adequate guarantees for civil liberties. Supporters of the Constitution in states where popular sentiment was against ratification (including Virginia, Massachusetts, and New York) successfully proposed that their state conventions both ratify the Constitution and call for the addition of a bill of rights. One charge of the Anti-Federalists was that giving the U.S. Supreme Court jurisdiction "both as to law and fact" would allow it to deny the findings of jury trials in civil cases. Responding to these concerns, five state ratification conventions recommended a constitutional amendment guaranteeing the right to jury trial in civil cases. Proposal and ratification In the 1st United States Congress, following the state legislatures' request, James Madison proposed twenty constitutional amendments based on state bills of rights and English sources such as the Bill of Rights 1689. Among them was an amendment protecting findings of fact in civil cases exceeding a certain dollar value from judicial review. Madison proposed that this amendment should be added directly to Article III, though Congress later determined to add the proposed Bill of Rights to the end of the Constitution, leaving the original text intact. Congress also reduced Madison's proposed twenty amendments to twelve, and these were proposed to the states for ratification on September 25, 1789. By the time the Bill of Rights was submitted to the states for ratification, opinions had shifted in both parties. Many Federalists, who had previously opposed a Bill of Rights, now supported the Bill as a means of silencing the Anti-Federalists' most effective criticism. Many Anti-Federalists, in contrast, now opposed it, realizing the Bill's adoption would greatly lessen the chances of a second constitutional convention, which they desired. Anti-Federalists such as Richard Henry Lee also argued that the Bill left the most objectionable portions of the Constitution, such as the federal judiciary and direct taxation, intact. On November 20, 1789, New Jersey