and reserve military organizations be treated as a single force. The Montgomery Amendment to the National Defense Authorization Act for Fiscal Year 1987 provides that a governor cannot withhold consent with regard to active duty outside the United States because of any objection to the location, purpose, type, or schedule of such duty. This law was challenged and upheld by the Supreme Court of the United States in 1990 in Perpich v. Department of Defense. The John Warner Defense Authorization Act of 2007 Federal law was changed in section 1076 so that the Governor of a state is no longer the sole commander in chief of their state's National Guard during emergencies within the state. The President of the United States could then take total control of a state's National Guard units without the governor's consent. In a letter to Congress, all 50 governors opposed the increase in power of the President over the National Guard. The National Defense Authorization Act of 2008 Repeals provisions in section 1076 in Pub.L. 109-364 but still enables the President to call up the National Guard of the United States for active federal military service during Congressionally sanctioned national emergency or war. Places the National Guard Bureau directly under the Department of Defense as a joint activity. Promoted the Chief of the National Guard Bureau from a three-star to a four-star general.The National Defense Authorization Act of 2012' Added the Chief, National Guard Bureau to the Joint Chiefs of Staff. Notable members Presidents Militia service was a common trait among presidents of the United States, 18 of whom have served in colonial or state militias and two have served in the National Guard since it was established in 1903. Among these, three served in colonial militias (George Washington, Thomas Jefferson and James Madison), 15 served in state militias (James Monroe, Andrew Jackson, William Henry Harrison, Millard Fillmore, Franklin Pierce, James Buchanan, Abraham Lincoln, Andrew Johnson, Ulysses S. Grant, Rutherford B. Hayes, James Garfield, Chester A. Arthur, William Henry Harrison, William McKinley and Theodore Roosevelt), one in the Army National Guard (Harry S. Truman) and one (George W. Bush) served in the Air National Guard. Other notable members John R. Bolton, former United States Representative to the United Nations and National Security Advisor Scott Philip Brown, former United States Senator from Massachusetts William J. Donovan, founder of the Office of Strategic Services Joe Foss, Governor