In this description, it will be observed, the adjective “constitutional” is reserved for the first kind of polity. In defending the 1787 Philadelphia Convention’s decision to submit the proposed constitution to specially elected state conventions instead of the state legislatures, Alexander Hamilton had stressed the need for recourse to the sovereign people. The previous instrument of government, the Articles of Confederation, was suspect exactly because it “never had a ratification by the people” and, therefore, “rest[ed] on no better foundation than the consent of the several legislatures.” The difficulties that had followed demonstrated “the necessity of laying the foundations of our national government deeper than in the mere sanction of delegated authority.” The academic debate on a European Constitution has rehearsed these concerns about constitution-making by intergovernmental agreement. Dieter Grimm, noting that this was the only realistic possibility for a near-term European constitution, insisted that such an arrangement could not be a “constitution in the full sense of the term. The difference lies in the reference back to the will of the Member States rather than to the people of the Union.”