Madison, later a congressman, drafted a bill of rights, drawing heavily upon the Virginia Declaration of Rights that was the work primarily of anti-federalist George Mason. Madison's First Amendment, modified in various ways of no great importance to us now, became law of the land in 1791" (Ostrowski 3). ... The Act was enforced against Republican papers in an effort to keep Jefferson's party from defeating the federalists in the 1800 election. ... In the end, as Learned Hand said, "Liberty lies in the hearts of men and women; when it dies there, no constitution or court can save ...