A Heritage Foundation legal memorandum by Thomas Jipping argues the National Popular Vote interstate compact—an agreement by 15 states and D.C. representing 196 electoral votes to award their electors to the national popular vote winner—is an unprecedented attempt to bypass the Constitution and replace the Electoral College without amending it. Jipping contends the compact enhances compacting states' political power at non-members' expense, so it requires congressional consent under the Supreme Court's Compact Clause rulings, and calls it bad policy even with that consent, predicting it would disenfranchise voters in states whose electoral votes go to candidates they rejected.