Of the following who argued that because slaves were legally considered property and were not alllowed to vote they should not be counted?

The argument that slaves, being legally considered property and denied the right to vote, should not be counted in apportioning representation was made by various proponents of slavery, but it is most notably associated with the position taken by the Southern states during the debates over representation in the U.S. Constitution. Specifically, this view was articulated by figures like James Madison and others who sought to ensure that slaveholding states would not gain undue political power through the counting of enslaved individuals. Ultimately, this led to the Three-Fifths Compromise, which counted each slave as three-fifths of a person for representation purposes.