In the course of the acrimonious debate over the judiciary, Federalists had challenged the constitutional right and power of Congress to vacate the judgeships, asserting that the plain intent of the Constitution is to place the judges beyond the power of Congress by prescribing a tenure of office during good behavior. The challenge was disquieting, for with John Marshall on the bench of the Supreme Court, the Republican reformation of the courts might be brought to naught by an adverse decision. A supplementary act was therefore passed which prevented the Supreme Court from holding its usual session. It was hoped that when the court met in the following year, Federalist partisanship would have lost its violence. Two obnoxious acts of the late Administration--the Alien and the Sedition Acts--had expired by limitation. Congress suffered the Alien Enemies Act to remain upon the statute book, but insisted upon the repeal of the Naturalization Act of the year 1798. The time of residence required of aliens before they could acquire citizenship was again fixed at five years. With these rather meager performances, the reforms of the Republicans came to an end. Perhaps none of the last appointments of John Adams had so exasperated his successor as that of John Marshall as Chief Justice of the Supreme Court. Jefferson had an invincible repugnance for Marshall; and the feeling was cordially reciprocated. Between these men there were temperamental differences as wide as the ocean. Moreover, Jefferson entertained the belief that all appointments made by Adams after the results of the election were known were nullities, on the theory that a retiring President might not bind his successor. Two years later, in 1803, in the famous case of _Marbury_ v. _Madison_, the Supreme Court, speaking through the Chief Justice, took sharp issue with the President. William Marbury had applied to the court for a _mandamus_ to compel Madison, Secretary of State, to deliver his commission as justice of the peace, which, it was alleged, had been duly signed and sealed, but never delivered. The Supreme Court held that Marbury was entitled to his commission. "To withhold his commission, therefore," said Marshall, "is an act deemed by the Court not warranted by law, but violative of a legal vested right." Let President Thomas Jefferson take notice of his constitutional obligations.