In the 1st United States Congress, following the state legislatures' request, James Madison proposed twenty constitutional amendments based on state bills of rights and English sources such as the Bill of Rights 1689. Among them was an amendment protecting findings of fact in civil cases exceeding a certain dollar value from judicial review. Madison proposed that this amendment should be added directly to Article III, though Congress later determined to add the proposed Bill of Rights to the end of the Constitution, leaving the original text intact. Congress also reduced Madison's proposed twenty amendments to twelve, and these were proposed to the states for ratification on September 25, 1789.