Article 197 of the 1991 Constitution of Colombia established an absolute prohibition on presidential re-election. This article was amended in 2004, establishing the limit of one re-election (the so-called “immediate re-election clause”). The amendment also introduced clauses aimed at leveling the political playing field, in view of the advantages that an incumbent president has, in terms of resources, media access and visibility. The Constitutional Court upheld the amendment, holding that allowing the immediate re-election of the incumbent President for one additional term did not amount to a “substitution” of the constitutional regime and was therefore constitutional and could be adopted by Congress. Under the amendment, President Uribe was allowed to hold a second term.