In the case of Rebecca McDowell Cook v. Donald J. Gralike and Mike Harman, 2000, the US Supreme Court ruled that a Missouri law was unconstitutional because it infringed on Congress's power to regulate its own elections. The law required labels on ballots indicating whether or not a candidate supported term limits for members of Congress. If they did not support term limits, their names would be marked with "disregarded voters' instruction on term limits" or if they had no previous record regarding this issue, their names would be labeled as "declined to pledge to support term limits". The court found that these labels were an attempt by the state to dictate qualifications for congressional service and influence election outcomes which is in violation of Article I of the Constitution.

In the dissenting opinion for Rebecca McDowell Cook v. Donald J. Gralike and Mike Harman, Justice Clarence Thomas argued that the Missouri constitutional amendment at issue did not violate Article I of the U.S. Constitution because it didn't bind or control federal legislators in any way but merely expressed a non-binding advisory opinion from constituents to their representatives about term limits. He contended that this was an exercise of state's rights under Tenth Amendment and part of democratic process where people can express their views on policy matters to elected officials without infringing upon federal legislative power structure established by constitution. Thus, he disagreed with majority's view that such amendments were unconstitutional attempts by states to dictate qualifications for congressional service beyond those specified in Constitution.