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The '''Report of 1800''' was issued by [[James Madison]] as an update to the [[Kentucky and Virginia Resolutions]]. In the resolution, Madison calls for individual states to use their Constitutional powers against the [[Alien and Sedition Acts]].
The report also issues a warning about [[Judicial Supremacy]], that if a judicial decision can be raised above the states, then dangerous powers which were not delegated to the federal government could be usurped. <ref>[https://blog.tenthamendmentcenter.com/2012/11/open-letter-to-the-states-to-stand-against-obamacare/ Open Letter to the States to Stand Against Obamacare]</ref> Madison wrote:
:If the decision of the judiciary be raised above the authority of the sovereign parties to the constitution, the decisions of the other departments, not carried by the forms of the constitution before the judiciary, must be equally authoritative and final with the decisions of that department. But the proper answer to the objection is, that the resolution of the General Assembly relates to those great and extraordinary cases, in which all the forms of the constitution may prove ineffectual against infractions dangerous to the essential rights of the parties to it. The resolution supposes that dangerous powers not delegated, may not only be usurped and executed by the other departments, but that the Judicial Department also may exercise or sanction dangerous powers beyond the grant of the constitution.
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