The protection of people's life and liberty is the core duty of all levels of government in the United States. The Declaration of Independence states that "Governments are instituted" to "secure" the "rights" to "Life, Liberty and the pursuit of Happiness." James Madison - the primary author of the Bill of Rights and Father of the Constitution - reiterated this at the Constitutional Convention and in the Federalist Papers. However, this principle wasn't explicitly codified in the Constitution until the passage of the 14th Amendment in 1868. Consequently, the U.S. Supreme Court ruled in 1911, "Primarily, governments exist for the maintenance of social order. Hence it is that the obligation of the government to protect life, liberty, and property against the conduct of the indifferent, the careless, and the evil-minded may be regarded as lying at the very foundation of the social compact."