“What, sir, is the use of a militia? It is to prevent the establishment of a standing army, the bane of liberty.”
-Elbridge Gerry. Vice President under James Madison.
As Thomas Jefferson made clear when he wrote the Kentucky Resolutions in 1798, Nullification is not something that’s permitted to the people of the states by any document – it’s their natural right to resist oppressive power. From this, one could easily posit that this right is one that the federal government is barred from infringing under the 9th Amendment.
The enumeration in the Constitution, of certain rights, shall not be construed to deny or disparage others retained by the people
More on the 9th in a future power. Here’s Jefferson:
“that every State has a natural right in cases not within the compact to nullify of their own authority all assumptions of power by others within their limits: that without this right, they would be under the dominion, absolute and unlimited, of whosoever might exercise this right of judgment for them”