Although written in 1776, its principles were applied a few years later in 1791 when the Bill of Rights was ratified to the United States Constitution. James Madison extensively used the Virginia document when drafting the Bill of Rights. Therefore, the document included amendments guaranteeing provisions such as the Free Exercise Clause and the prevention of cruel and unusual punishment, which mirrors the Virginia Declaration of Rights almost exactly. The Bill of Rights is still used as the primary reference of human rights within the United States and continues to secure liberties in the court of law. For instance, in the 2005 case of McCreary County v. ACLU courts upheld the Establishment clause when a courthouse in Kentucky displayed the Ten Commandments, which is illegal because it preferences a particular