During debate on the 2004 Commerce, Justice, and State appropriations bill, Congressman Levin (D-MI) proposed an amendment which would have prevented the U.S. from entering into any free trade agreement with a Central American country that failed to: 1) protect U.S. copyrights from patent infringements; 2) ensure open markets for U.S. agricultural goods; and 3) uphold fair labor standards. Progressives voted in favor of Levin's proposal because, in their view, free trade should be a two-way street; allowing foreign countries to circumvent U.S. copyright laws, block the sale of U.S. agricultural products in their country, or fail to uphold labor agreements, Progressives argued, unfairly penalized American businesses, farmers, and laborers. Representative Kolbe (R-AZ) raised a point of order against the Levin amendment on the grounds that the measure constituted legislation in an appropriations bill (appropriations bills are considered privileged matters in the House and Senate; amendments to spending bills which are not deemed germane (relevant) to the pending legislation can be subject to a point of order). The subject of this vote was a motion to sustain Kolbe's point of order against the Levin amendment. Although Progressives voted against the point of order based on their support for Levin's amendment, Kolbe's objection was sustained 231-198, Levin's amendment was defeated, and the trade protections for U.S. workers and businesses were not included in the underlying spending bill.