Story responded by writing an opinion that clearly established the power of the U.S. Supreme Court to review state supreme court decisions. He upheld the constitutionality of Section 25 of the Judiciary Act of 1789, writing that “the appellate power of the United States must … extend to state tribunals.” Jean Edward Smith, in his biography of Chief Justice Marshall, entitled John Marshall: Definer of a Nation, writes: “Martin v. Hunter’s Lessee provided the rationale for the supremacy of the Union.”