161 It is also why the Philadelphia Convention of 1787 that drafted the United States Constitution felt justified in by-passing the approval of state legislatures and submitting the instrument to special conventions to be called in each state.162When those conventions had approved it, it was understood *746 to have received the assent of the people. “The people acted upon it,” Chief Justice Marshall was later to say “in the only manner in which they can act safely, effectively and wisely,on such a subject, by assembling in Convention.”163 This is the “body of extraordinary representatives” of which Sieyès wrote that it “takes the place of the assembly of the nation