After 1820 the pendulum swung rapidly back toward particularism. State rights sentiment was freely expressed by men, both Southern and Northern, whose views commanded respect; and in more than one State--notably in Ohio and Georgia--bold actions proclaimed this sentiment to be no mere matter of academic opinion. Ohio in 1819 forcibly collected a tax on the United States Bank in defiance of the Supreme Court's decision in the case of M'Culloch vs. Maryland; and in 1821 her Legislature reaffirmed the doctrines of the Virginia and Kentucky resolutions and persisted in resistance, even after the Supreme Court had rendered a decision π specifically against the position which the State had taken. Judge Roane of Virginia, in a series of articles in the Richmond Enquirer, argued that the Federal Union was a compact among the States and that the nationalistic reasoning of his fellow Virginian, Marshall, in the foregoing decisions was false; and Jefferson heartily endorsed his views. In Cohens vs. Virginia, in 1821, the Supreme Court held that it had appellate jurisdiction in a case decided by a state court where the Constitution and laws of the United States were involved, even though a State was a party; whereupon the Virginia House of Delegates declared that the State's lawyers had been right in their contention that final construction of the Constitution lay with the courts of the States. Jefferson, also, gave this assertion his support, and denounced the centralizing tendencies of the Judiciary, "which, working like gravity without any intermission, is to press us at last into one consolidated mass." π Osborn vs. Bank of the United States. In 1825 Jefferson actually proposed that the Virginia Legislature should pass a set of resolutions pronouncing null and void the whole body of federal laws on the subject of internal improvements. The Georgia Legislature, aroused by growing antislavery activities in the North, declared in 1827 that the remedy lay in "a firm and determined union of the people and the States of the South" against interference with the institutions of that section of the country. Already Georgia had placed herself in an attitude of resistance to the Federal Government upon the rights of the Indians within her borders, and within the next decade she repeatedly nullified decisions of the federal courts on this subject. In 1828 the South Carolina Legislature adopted a series of eight resolutions denouncing the lately enacted "tariff of abominations," and a report, originally drafted by Calhoun and commonly known as The South Carolina Exposition, in which were to be found all of the essentials of the constitutional argument underlying the nullification movement of 1832.