Virginia delegate James Madison realized that too much power in any one branch could create problems when he wrote in the Federalist Papers (#47): “The accumulation of all powers, legislative, executive and judiciary, in the same hands, whether of one, a few or many, and where hereditary, self-appointed, or elective, may justly be pronounced the very definition of tyranny.” Madison actually favored a system whereby the justices would join with members of the executive branch to form a “council of revision” that would review laws proposed by the U.S. Congress.