In feudal or monarchical constitutional theory, individuals were the subjects of a monarch or sovereign, but the republican constitutional theory of therevolutionary and post-revolutionary period conceived of the individual as a citizen andassigned sovereignty to the people. The distinction between citizens and subjects is reflected in Chief Justice John Jay’s opinion in Chisholm v. Georgia, [2 U.S. (2 Dall.)419 (1793)the first great constitutional case decided after the ratification of the Constitution of 1789: [T]he sovereignty of the nation is in the people of the nation, and the residuary sovereignty of each State in the people of each State . ....