The Third Amendment says no soldier can be quartered in any house during peacetime without the owner''s consent, or during war except as prescribed by law. This responded directly to British Parliament''s Quartering Acts of 1765 and 1774, which forced colonists to house British troops in barracks, inns, stables, and alehouses—and during the Intolerable Acts of 1774, potentially in private homes. Patrick Henry called quartering ''one of our first complaints'' and ''one of the principal reasons for dissolving the connection with Great Britain.'' The amendment is the least litigated part of the Bill of Rights—the Supreme Court has never decided a case based on it. The only significant case, Engblom v. Carey (1982), involved National Guard troops housed in prison employee dorms during a strike. The Second Circuit ruled that National Guard members count as soldiers, tenants count as owners, and the Third Amendment applies to states through the Fourteenth Amendment.