Compiling a manual of parliamentary practice in 1801, Thomas Jefferson emphatically recognized the importance of procedure in securing the rights of minority party members in the U.S. Congress. In a democratic political institution, majorities would achieve their favored outcomes by taking advantage of their superior size, and minorities would resist by availing themselves of protective rules to amend, delay, or obstruct the majority's agenda. Yet, as suggested by Representative Archibald McBryde (Federalist-North Carolina) in a public letter to constituents just a few years later, the portrait of congressional rules as stable guarantors of the minority party's right to participate meaningfully in the legislative process is deceptive.