The U.S. Supreme Court has issued various decisions that require state governments to respect most of the rights in the Bill of Rights but not all of them. In these cases, the majority of Justices invoked a doctrine called "selective incorporation." Under this invention of the Court, state governments don't have to honor all Constitutional rights but merely those that the Court deems "fundamental" to the American "scheme of ordered liberty." In the 2010 case of McDonald v Chicago, 4 of the 9 Supreme Court justices claimed that the right to keep and bear arms doesn't meet that standard. In contrast, when U.S. Senator Jacob Howard introduced the 14th Amendment in 1866, he stated that its primary purpose is "to restrain the power of the States and compel them at all times to respect" the "personal rights guaranteed and secured by" the Bill of Rights, including "the right to keep and to bear arms" and all of the others.