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In page Virginia Declaration of Rights:

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Virginia's western counties cited the Declaration of Rights as a justification for rejecting the state's Ordinance of Secession before the American Civil War. The delegates to the Wheeling Convention argued that under the Declaration of Rights, any change in the form of government had to be approved by a referendum. Since the Secession Convention had not been convened by a referendum, the western counties argued that all of its acts were void. This set in motion the chain of events that ultimately led the western counties to break off as the separate state of West Virginia.[citation needed]