“Each State then reserves its own rights to itself, and the [Virginia] Resolutions affirm, that the right to refuse obedience to an unconstitutional law, is among those reserved rights. Again: if the State may not act upon its own decision, until the majority have sanctioned it, the right so to decide, is, until the majority have sanctioned it, in that majority, and not in the State. The State has only the right to express its opinion; which opinion although involving her ‘safety,’ and her very existence, goes for nothing until approved by others.” – Abel P. Upshur
Some, such as Matt Spalding a the Heritage Foundation, argue only all of the states working together can legitimately nullify an unconstitutional act. The 19th century Virginia jurist obliterates that foolish notion. Nullification is a natural right of self-defense reserved to the states and the people.