The Report of 1800 was a resolution drafted by James Madison (pictured), arguing for the sovereignty of the individual states under the United States Constitution and against the Alien and Sedition Acts. The Virginia General Assembly adopted the Report in January 1800. The document primarily subtly amends arguments from the 1798 Virginia Resolutions, and the main reason for producing the Report was to answer criticisms that had been leveled at the Resolutions. The arguments made in the Resolutions and the Report were later used frequently during the nullification crisis of 1832, when South Carolina declared federal tariffs to be unconstitutional and void within the state. Madison, however, rejected the concept of nullification and the notion that his arguments supported such a practice. Whether Madison's theory of republicanism really supported the nullification movement, and more broadly whether the ideas he expressed between 1798 and 1800 are consistent with his work before and after this period, are the main questions surrounding the Report in the modern literature.