Judiciary Act of 1801 - Passed by the expiring Federalist Congress. Adams signed in "midnight judges", one of them being John Marshall.
Madison's Gamble. Napoleon saw his chance with Macon's Bill No 2 -- Madison "gambled" that the threat of seeing the US trade exclusively with France would lead British to repeal their restrictions. He accepted the French offer as evidence of repeal. His gamble failed and he saw no choice but to re-establish the embargo against Britain alone -- meant the end of neutrality.