Protest against the prospect and the constitutionality of higher tariffs began in 1826 and 1827 with William Branch Giles, who had the Virginia legislature pass resolutions denying the power of Congress to pass protective tariffs, citing the Virginia Resolutions of 1798 and James Madison's 1800 defense of them. Madison denied both the appeal to nullification and the unconstitutionality; he had always held that the power to regulate commerce included protection. Jefferson had, at the end of his life, written against protective tariffs.