Jefferson believed that a Bill of Rights was necessary to protect civil liberties and that, without a list of protected rights, the government could abuse its power. As a result, the Bill of Rights protects personal expression and property and legal rights. Madison, on the other hand, thought listing specific rights could ultimately limit the unmentioned rights that also needed to be protected. His concerns were answered by the inclusion of the Ninth and Tenth Amendments, which address the rights not specifically listed in the Constitution.