One had to rely on the doctrine of incorporation by reference and consider the text of the void first proclamation to give the second proclamation meaning.
2.
Following the ratification of the Fourteenth Amendment to the United States Constitution and through the doctrine of incorporation, this restriction is held to be applicable to state governments as well.
3.
The doctrine of incorporation, which had first taken root in " Gitlow v . New York ", was applied fully to most provisions of the Bill of Rights.
4.
In 1925, the Supreme Court made a landmark ruling in " Gitlow v . New York ", establishing the doctrine of incorporation, under which provisions of the Bill of Rights were deemed to restrict the states.
5.
Senator Orrin Hatch gave further arguments about the Doctrine of Incorporation, and further reviewed Sotomayor's statement of " fidelity to the law . " Hatch also brought up the right to privacy, and the fact that Sotomayor had stated that the Constitution " cannot be bent, " and that courts " can apply the words of the Constitution to the facts of the case before them . " Hatch next brought up once again the issue of " empathy " in judicial ruling.