disavowing almost entirely any role for judicial review of Congressional spending policies, thereby conferring upon Congress a plenary power to impose taxes and to spend money for the general welfare subject almost entirely to Congress's own discretion. In South Dakota v. Dole (1987) the Court held Congress possessed power to indirectly influence the states into adopting national standards by withholding, to a limited extent, federal funds where a state did not meet certain conditions required by Congress. Following that ruling, the Court later held by a 7–2 vote in National Federation of Independent Business v. Sebelius (2012) that Congress conditioning a state's receipt of the entirety of its federal Medicaid funds on whether said state elected to expand its Medicaid program in accordance with the Patient Protection and Affordable Care Act was an unconstitutionally coercive use of Congress's spending power. To date, the Hamiltonian view of the General Welfare Clause predominates in case law. Historically, however, the Anti-Federalists were wary of such an interpretation of this power during the ratification debates in the 1780s. Due to the objections raised by the Anti-Federalists, Madison was prompted to author his contributions to The Federalist Papers, attempting to quell the Anti-Federalists' fears of any such abuse by the proposed national government and to counter Anti-Federalist arguments against the Constitution. Proponents of the Madisonian view also point to Hamilton's limited participation in the Constitutional Convention, particularly during the time frame in which this clause was crafted, as further evidence of his lack of constructive authority. An additional view of the General Welfare Clause that is not as well known, but just as authoritative as the views of both Madison and Hamilton, can be found in the pre-Revolutionary writings of John Dickinson, who was also a delegate to the Philadelphia Convention. In his Letters from a Farmer in Pennsylvania (1767), Dickinson wrote of what he understood taxing for the general welfare entailed: The idea Dickinson conveyed above, explains University of Montana Law Professor Jeffrey T. Renz, is that taxing for the general welfare is but taxation as a means of regulating commerce. Renz expands upon this point: Comparative view The narrow construction of the General Welfare Clause is unusual when compared to similar clauses in most state constitutions, and many constitutions of other countries. Virtually every state constitution has a general welfare clause which is interpreted as granting the state an independent power to regulate