The quotation "All men are create equal" is arguably the best-known phrase in any of America's political documents, as the idea it expresses is generally considered the foundation of American democracy. Thomas Jefferson first used the phrase in the Declaration of Independence as a rebuttal to the going political theory of the day: the Divine Right of Kings. None of Jefferson's biographers or studies of the Declaration accept the claim that the phrase was suggested by Philip Mazzei, although this claim has been made by non-scholars.