For the past 30 years, all of the Supreme Court justices appointed by Democrats have ruled that the Second Amendment's "right of the people to keep and bear Arms" does not actually apply to the people. Instead, they ruled that it only applies to individuals who serve in militias, which they claim are the state National Guard units. In other places where the Constitution uses the phrase "right of the people," there is universal agreement that these rights apply to the people, not just individuals who work for government. James Madison, the primary author of the 2nd Amendment, wrote that "being armed" is an "advantage" that "Americans possess over the people of almost every other nation." Likewise, the Senator who introduced the 14th Amendment said that its purpose is to "restrain the power of the States and compel them at all times to respect" the "personal rights guaranteed and secured by the first eight amendments of the Constitution," including "the right to keep and to bear arms."