<P> The Third Amendment is among the least cited sections of the U.S. Constitution . In the words of Encyclopædia Britannica, "as the history of the country progressed with little conflict on American soil, the amendment has had little occasion to be invoked ." To date, no major Supreme Court decision has used the amendment as its primary basis . </P> <P> The Third Amendment has been invoked in a few instances as helping establish an implicit right to privacy in the Constitution . Justice William O. Douglas used the amendment along with others in the Bill of Rights as a partial basis for the majority decision in Griswold v. Connecticut (1965), which cited the Third Amendment as implying a belief that an individual's home should be free from agents of the state . </P> <P> In one of the seven opinions in Youngstown Sheet & Tube Co. v. Sawyer (1952), Justice Robert H. Jackson cited the Third Amendment as providing evidence of the Framers' intent to constrain executive power even during wartime: </P> <P> "(t) hat military powers of the Commander in Chief were not to supersede representative government of internal affairs seems obvious from the Constitution and from elementary American history . Time out of mind, and even now in many parts of the world, a military commander can seize private housing to shelter his troops . Not so, however, in the United States, for the Third Amendment says...(E) ven in war time, his seizure of needed military housing must be authorized by Congress ." </P>

What is one reason that the framers include the third amendment in the bill of rights