In correspondence to the Court's analysis in "Thornton" of the 1787 Constitutional Convention and the history of state-imposed term limits and additional qualifications for members of Congress, Williams notes that the Convention explicitly rejected a proposal to elect the President by a national popular vote, and that all of the systems adopted by state legislatures to appoint electors in the wake of the ratification of the Constitution (direct appointment by the state legislature, popular election by electoral district, statewide winner-takes-all election) appointed electors directly or indirectly in accordance with voter sentiment within their respective states and not on the basis of votes cast outside of their states. Likewise, in correspondence to the Court's analysis of congressional elections history, Williams notes that no state has ever appointed their electors in accordance with the national popular vote—even though every state since the 1880 election has conducted a statewide vote to appoint its electors, which would enable the statewide vote counts to be aggregated. The CRS report and Williams also note that the Court in "McPherson v. Blacker" was upholding a law passed by the Michigan Legislature to appoint its electors by popular vote in electoral districts, and in contrast to the NPVIC, in accordance with voter sentiment within Michigan rather than the country as a whole.