One of Hamilton's primary arguments for a unitary executive was that it increases accountability for executive action, thereby protecting liberty. Many have argued that the Bush administration's and Obama administration's use of secrecy and unilateral executive action has violated American liberty. One scholar, James Pffifner, claims that if Hamilton were alive today, he would amend Federalist No. 70 to say that the "energy of the executive needs to be balanced by the 'deliberation and wisdom that only the legislature can provide.'"