In Marbury v. Madison the power of judicial review was granted to the Supreme Court in 1801. The Constitution does not confer the power of judicial review. On Adams' last day in office, several government officials made the case. Judicial review does not exist in countries that have a centralized or unitary form of government. The elected parliament declares it to be the law of the land. Halsema's proposal to the Netherlands took the initiative to initiate the process of judicial review. President John Adams and the Federalist lost the election to Thomas Jefferson. The lame-duck federalist in Congress enacted a law on the judiciary. The act created 58 new judges appointed by Adams. Forty-two included justices of the peace. “Jefferson complained that the Federalists 'have retreated into the judiciary like a stronghold'” (Black, n.d.). Toward the end of the Adams presidency, many people besides Marbury were appointed to government positions. Acting Secretary of State John Marshall had affixed the official seal of the Justices of the Peace to the commissions. However they were not delivered until the day after Adams left office. The day after Thomas Jefferson's inauguration; James Madison was the new Secretary of State and was tasked with withholding the delivery of the commissions which included William Marbury and 16 others. Murbury sued to have the commission delivered by Madison. Because of the presidential seal of the United States, Marbury had the right to judicial review because the seal made it official. The Supreme Court was responsible for all cases which included public ministers, consuls and ambassadors. Having this case gave the Supreme Court the power of judicial review. The decision rests with central government...... middle of document......recordsearch.org/137/judicial-review-in-the-netherlands/Black , C. (nd). Exploring constitutional conflicts. Retrieved March 17, 2010, from www.law2.umkc.edu: http://law2.umkc.edu/faculty/projects/ftrials/conlaw/judicialrev.htmMeadows, N. (2001). The English government. Retrieved March 17, 2011, from www.library.thinkquest.org: http://library.thinkquest.org/J0112187/england_government.htmPGCPS. (n.d.). Government systems: unitary, confederate and federal systems. Retrieved March 17, 2011, from www. pgcps.org: www.pgcps.org/~croom2/Reading_Government%20Systems.docQuirk, W., & Bridwell, B. (1996). Judicial dictatorship. Retrieved March 17, 2011, from www.mises.org: http://mises.org/misesreview_detail.aspx?control=134State, UD (n.d.). Background note: Netherlands. Retrieved March 17, 2011, from www.state.gov: http://www.state.gov/r/pa/ei/bgn/3204.htm