Beetz also participated in the 1981 Patriation Reference, which considered Prime Minister Pierre Trudeau's attempt to have the federal government unilaterally patriate the Constitution of Canada without the consent of the provinces. By a 7-2 division, a majority of the Court held that Parliament had the legal authority to act unilaterally. However, by a division of 6-3, the Court also held that unilateral federal action would violate a constitutional convention that had emerged since Confederation, requiring substantial provincial agreement on constitutional amendments.