direct taxation, intact. On November 20, 1789, New Jersey ratified eleven of the twelve amendments, rejecting ArticleII, which regulated Congressional pay raises. On December 19 and 22, respectively, Maryland and North Carolina ratified all twelve amendments. On January 19, 25, and 28, 1790, respectively, South Carolina, New Hampshire, and Delaware ratified the Bill, though New Hampshire rejected the amendment on Congressional pay raises, and Delaware rejected ArticleI, which regulated the size of the House. This brought the total of ratifying states to six of the required ten, but the process stalled in other states: Connecticut and Georgia found a Bill of Rights unnecessary and so refused to ratify, while Massachusetts ratified most of the amendments, but failed to send official notice to the Secretary of State that it had done so. In February through June 1790, New York, Pennsylvania, and Rhode Island ratified eleven of the amendments, though all three rejected the amendment on Congressional pay raises. Virginia initially postponed its debate, but after Vermont was admitted to the Union in 1791, the total number of states needed for ratification rose to eleven. Vermont ratified on November 3, 1791, approving all twelve amendments, and Virginia finally followed on December 15, 1791. Secretary of State Thomas Jefferson announced the adoption of the ten successfully ratified amendments on March 1, 1792. Judicial interpretation The Third Amendment is among the least cited sections of the U.S. Constitution. In the words of Encyclopædia Britannica, "as the history of the country progressed with little conflict on American soil, the amendment has had little occasion to be invoked." To date, no major Supreme Court decision has used the amendment as its primary basis. The legal historian Tom W. Bell argued in 1993 that the quartering of American soldiers during the War of 1812 and American Civil War violated the Third Amendment, but this argument was never presented in court during either war. Following the Civil War, the Army compensated property owners for rent and damages, which may have preempted Third Amendment claims. The Third Amendment has been invoked in a few instances as helping establish an implicit right to privacy in the Constitution. Justice William O. Douglas used the amendment along with others in the Bill of Rights as a partial basis for the majority decision in Griswold v. Connecticut (1965), which cited the Third Amendment as implying a belief that an individual's home should be