variations of mass sentiment, would be elected by the lower house.

Under the Articles of Confederation, Congress was a unicameral body in which each state held one vote. The ineffectiveness of the federal government under the Articles led Congress to summon a Constitutional Convention in 1787; all states except Rhode Island agreed to send delegates. The issue of how Congress was to be structured was one of the most divisive among the founders during the Convention. James Madison's Virginia Plan called for a bicameral Congress: the lower house would be "of the people," elected directly by the people of the United States and representing public opinion, and a more deliberative upper house that would represent the individual states, and would be less susceptible to variations of mass sentiment, would be elected by the lower house.

The House is referred to as the lower house, with the Senate being the upper house, although the United States Constitution does not use that terminology. Both houses' approval is necessary for the passage of legislation. The Virginia Plan drew the support of delegates from large states such as Virginia, Massachusetts, and Pennsylvania, as it called for representation based on population. The smaller states, however, favored the New Jersey Plan, which called for a unicameral Congress with equal representation for the states.

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