North Carolina and Rhode Island hold out initially

In August 1788, the North Carolina ratifying convention at Hillsborough voted 184 to 84 to neither ratify nor reject the Constitution until a bill of rights was guaranteed. Rhode Island refused even to call a ratifying convention and instead sent the Constitution to a popular referendum in March 1788, where voters rejected it by 2,711 to 239. As a result, both states remained outside the Union when George Washington was inaugurated on April 30, 1789 and when the First Congress began business in New York.

The holdout by North Carolina and Rhode Island showed that Anti-Federalist resistance was not a debating posture but a practical barrier to national union. Leaders in both states believed the Constitution gave excessive power to the central government and lacked explicit protections for religion, jury trial, and other liberties. Their refusal intensified pressure on Federalists to prove that the new government could answer ratification fears without reopening the Constitution itself.

North Carolina ratified on November 21, 1789 after Congress had proposed the Bill of Rights in September 1789, satisfying the demand that had dominated Hillsborough. Rhode Island followed on May 29, 1790 by the narrow vote of 34 to 32 after Congress threatened to treat it as a foreign nation for trade purposes, confirming how directly the Bill of Rights campaign helped complete the Union.