that the federal Wild Horse and Burro Act was a constitutional exercise of congressional power under the Property Clause at least insofar as it was applied to a finding of trespass. The case prohibited the entering upon the public lands of the United States and removing wild burros under the New Mexico Estray Law. A major issue early in the 20th century was whether the whole Constitution applied to the territories called insular areas by Congress. In a series of opinions by the Supreme Court of the United States, referred to as the Insular Cases, the Court ruled that the territories belonged to, but were not part of the United States. Therefore, under the Territorial clause, Congress had the power to determine which parts of the Constitution applied to the territories. These rulings have helped shape public opinion among Puerto Ricans during the ongoing debate over the commonwealth's political status. Section 4: Obligations of the United States Clause 1: Republican government This clause, sometimes referred to as the Guarantee Clause, has long been at the forefront of the debate about the rights of citizens vis-à-vis the government. The Guarantee Clause mandates that all U.S. states must be grounded in republican principles such as the consent of the governed. By ensuring that all states must have the same basic republican philosophy, the Guarantee Clause is one of several portions of the Constitution which mandates symmetric federalism between the states. The Constitution does not explain what exactly constitutes a republican form of government. There are, however, several places within it where the principles behind the concept are articulated. Article Seven, the last and shortest of the Constitution's original articles, stipulated that the Constitution, before it could become established as the "Law of the Land", must obtain the consent of the people by being ratified by popular conventions within the several states. Additionally, as it required the ratification of only nine states in order to become established, rather than the unanimous consent required by the Articles of Confederation, the Constitution was more republican, as it protected the majority from effectively being ruled or held captive by the minority. The Federalist Papers also gives some insight as to the intent of the Founders. A republican form of government is distinguished from a direct democracy, which the Founding Fathers had no intentions of entering. As James Madison wrote in Federalist No. 10, "Hence it is