Texas Gov. Rick Perry during Mike Huckabee's presidential candidate forum demanded that Supreme Court justices have term limits because of decisions he finds "offensive" regarding organized prayer and the placement of the Ten Commandments on government grounds. He said that Justices John Roberts and Samuel Alito are his models for the courts because they were "strict constructionists." When asked what strict constructionism means in layman's terms, he pulled out the Constitution, holding it upside down, and argued that the current Justices have strayed from it by using the Commerce Clause. As explained in a recent People For the American Way Foundation report, the Commerce Clause has been "the most important constitutional instrument for social progress in our history."