Roane, Jefferson's protégé, was still more violent and wrote a series of unrestrained papers at this time in the Richmond Enquirer, under the pseudonym "Algernon Sidney." Alluding to these, Marshall wrote Story that "their coarseness and malignity would designate the author of them if he was not avowed." Marshall himself thought to answer Roane, but quickly learned that the Virginia press was closed to that side of the question. He got his revenge, however, by obtaining the exclusion of Roane's effusions from Hall's Law Journal, an influential legal periodical published in Philadelphia. But the personal aspect of the controversy was the least important. "A deep design," Marshall again wrote his colleague, "to convert our Government into a mere league of States has taken hold of a powerful and violent party in Virginia. The attack upon the judiciary is in fact an attack upon the Union." Nor was Virginia the only State where this movement was formidable, and an early effort to repeal Section XXV was to be anticipated. That the antijudicial movement was extending to other States was indeed apparent. The decision in Sturges vs. Crowinshield ¹ left for several years the impression that the States could not pass bankruptcy laws even for future contracts and consequently afforded a widespread grievance. Ohio had defied the ruling in M'Culloch vs. Maryland, and her Treasurer was languishing in jail by the mandate of the Federal Circuit Court. Kentucky had a still sharper grievance in the decision in Green vs. Biddle, ² which invalidated a policy she had been pursuing for nearly a quarter of a century with reference to squatters' holdings; and what made the decision seem the more outrageous was the mistaken belief that it had represented the views of only a minority of the justices. ¹ 4 Wheaton, 122. ² 8 Wheaton, 1.