Ratified in 1868, the 14th Amendment strengthened citizenship rights and applied the Fifth Amendment’s due process protections to state governments. Some consider it a delayed affirmation of Thomas Jefferson’s promise in the Declaration of Independence that “all men are created equal.” In a sense, the 14th Amendment is an extension of the Bill of Rights—the first 10 Amendments assert many freedoms that the federal government must respect, and the 14th Amendment claims that the state governments may not violate these freedoms either. In fact, James Madison wanted to include an amendment with this purpose in the Bill of Rights, but at the time, Congress rejected his idea. The 14th Amendment includes five clauses: the Citizenship Clause, Privileges or Immunities Clause, Due Process Clause, Equal Protection Clause, and Enforcement Clause. The Due Process Clause is one of the most important; it protects many fundamental freedoms from the right to an attorney all the way to the more recent right to marriage regardless of sex. The Equal Protection Clause is also considered key; it finally transfers the promise of equality in Declaration of Independence to the Constitution. The 14^th Amendment also effectively overturned the Supreme Court’s infamous 1857 Dred Scott decision.