an unconstitutional encroachment upon the President. In 2007, University of Virginia Professor Larry J. Sabato proposed, in his book A More Perfect Constitution, a constitutional amendment that would settle the issue by spelling out the exact powers of each branch in the Constitution itself. One counterargument is that the Constitution is a "living document" that has survived for over 200 years because not everything is "spelled out." In the area of the War Powers Clause, the flexibility provided by the requirement for a congressional statute for a declaration of war and constitutional interpretation could be sufficient. The President could defend the country himself but not use the military offensively without Congress. That would not require a constitutional amendment or a statute like the War Powers Resolution since it has been used since 1787. Some legal scholars maintain that offensive, non-police military actions, while a quorum can still be convened (see Continuity of Government), taken without a formal congressional declaration of war is unconstitutional since no amendment has changed the original intent to make the War Powers Resolution legally binding. However, the US Supreme Court has never ruled directly on the matter and no counterresolutions has come to a vote. In the absence of a determination by the Supreme Court, the principle of separation of powers produces a stalemate on the issue. Constitutional convention debate Pierce Butler of South Carolina was the only delegate to the Philadelphia Convention who suggested giving the executive the power to take offensive military action. He suggested that even if the President should be able to do so, he, in practice, would have the character not to do so without mass support. Elbridge Gerry, a delegate from Massachusetts, summed up the majority viewpoint saying he "never expected to hear in a republic a motion to empower the Executive alone to declare war." George Mason, Thomas Jefferson, and other contemporaries voiced similar sentiments. War Powers Reform Congress has at various points sought to reassert its constitutional responsibility over war powers decisions, including since its enactment of the War Powers Resolution in 1973. In 2021, the House Rules Committee and the House Foreign Affairs Committee held hearings on war powers reform, at which testified several war powers scholars and former government officials. Supreme Court cases Woods v. Cloyd W. Miller Co. (1948) Youngstown Sheet & Tube Co. v. Sawyer (1952) Torres v. Texas Department of Public Safety (2021)