In Dillon v. Gloss, the U.S. Supreme Court observes that while there is no time limit for ratification of a constitutional amendment in the Constitution, Congress may specify one, as it did with Prohibition. The Court rules that a “fair … implication from Article V is that the ratification must be within some reasonable time after the proposal.” In 1921, the Court notes that “four amendments proposed long ago – two in 1789, one in 1810 and one in 1861 – are still pending.”