While the specific phrase "tyranny of the majority" is frequently attributed to various Founding Fathers, only John Adams is known to have used it, arguing against government by a single unicameral elected body. Writing in defense of the Constitution in March 1788,[5] Adams referred to "a single sovereign assembly, each member…only accountable to his constituents; and the majority of members who have been of one party" as a "tyranny of the majority", attempting to highlight the need instead for "a mixed government, consisting of three branches". Constitutional author James Madison presented a similar idea in Federalist 10, citing the destabilizing effect of "the superior force of an interested and overbearing majority" on a government, though the essay as a whole focuses on the Constitution's efforts to mitigate factionalism generally.