In modern scholarship outside the legal arena the Report is mostly studied for its discussion of states' rights with regard to federalism and republicanism. According to Kevin Gutzman, the Report, together with the Kentucky and Virginia Resolutions, forms a foundation for the "radical southern states' rights tradition." However, Madison rebuffed charges that his writings supported the constitutional interpretation advanced by pro-nullification Southerners. The Report of 1800, Madison argued, did not say the government was a compact of the individual states, as the pro-nullification elements suggested. Rather the Report of 1800 described a compact of "the people in each of the States, acting in their highest sovereign capacity." The state governments themselves, no less than the federal judiciary, possess only delegated power and therefore cannot decide questions of fundamental importance. Madison thought the Resolutions and Report were consistent with this principle while the Ordinance of Nullification was not.