Based on the above quotation, it was noted by the lawyer William J. Olson in an "amicus curiae" in the case "Hedges v. Obama" that the Treason Clause was one of the enumerated powers of the federal government. He also stated that by defining treason in the U.S. Constitution and placing it in Article III "the founders intended the power to be checked by the judiciary, ruling out trials by military commissions. As James Madison noted, the Treason Clause also was designed to limit the power of the federal government to punish its citizens for 'adhering to enemies [of the United States by, giving them aid and comfort.'"