At the very outset of America's republic, the Framers rightly anticipated the dangers inherent to any form of government which pits the rights of people against the rights of property. James Madison communicated his observations on this threat in October of 1788, stressing that "the bulk of the people" ought first to be sufficiently invested in property, or the prospects of the rights of property, with still a sufficient interest in the rights of persons. Madison sharply described the inevitable power to be suffered at the hands of those "not interested in the rights of property." In his observations he warned that "one of two things cannot fail to happen" in such a clash of interests: "either they will unite against the other description and become the dupes and instruments of ambition, or their poverty and independence will render them mercenary instruments of wealth." Madison then concluded that, "In either case liberty will be subve