In 1801 secretary of state John Marshall failed to deliver the commissions for President John Adams’ last minute judicial appointments, including William Marbury. Marbury’s commission as justice of the peace in the District of Columbia was withheld by the incoming secretary of state, James Madison. Marbury petitioned the Supreme Court to force Madison to deliver his commission. Chief Justice John Marshall opined for the court that even though Madison’s refusal to deliver the commission was illegal, the 13th section of the Judiciary Act of 1789 that enabled Marbury to bring the claim to the court was unconstitutional because it gave the Supreme Court original jurisdiction the Constitution did not grant. In declaring Section 13 illegal, Chief Justice Marshall gave the Supreme Court the power of judicial review to strike down laws it deemed unconstitutional.