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The amendment is one of the least controversial of the Constitution and is rarely litigated, to date, it has never been the primary basis of a Supreme Court decision, though it was the basis of the Court of Appeals for the Second Circuit case Engblom v. Carey. After the Boston Tea Party, the Quartering Act of 1774 was enacted, One of the Intolerable Acts that pushed the colonies toward revolution, it authorized British troops to be housed wherever necessary, including in private homes.]