Page "Marbury v. Madison" Paragraph 13

A number of legal scholars argue that the power of judicial review in the United States predated Marbury, and that Marbury was merely the first Supreme Court case to exercise a power that already existed and was acknowledged.

These scholars point to statements about judicial review made in the Constitutional Convention and the state ratifying conventions, statements about judicial review in publications debating ratification, and court cases before Marbury that involved judicial review.