After his defeat in the election of 1800 John Adams (with the outgoing Federalist Congress) passed the Judiciary Act of 1801, more generally known as the 'Midnight Judges Act.' This act passed 19 days before the end of his administration created 16 new positions for Circuit court positions which Adams immediately filled with Federalists; the so called 'Midnight Judges.'. This effort was largely unsuccessful as Jefferson quickly moved to repeal it. Ironically, the main lasting effect of the law would come later in Marbury vs. Madison, the famous Supreme Court case which established the power of judicial review. Marbury was one of the midnight judges, and he sued the Jefferson administration to deliver his commission.