William Marbury sued James Madison after Secretary of State Madison refused to deliver Marbury's commission as justice of the peace, which had been signed by former President Adams. The Supreme Court took up the case and established the precedent of judicial review by ruling that Section 13 of the Judiciary Act of 1789 was unconstitutional, though they did not force Madison to deliver the commission to Marbury. This case set important precedents around judicial review and checks and balances between branches of government.