Lame-duck Congress passes Judiciary Act of 1801 to pack federal courts with Federalist judges before Jefferson takes office

The Federalist-controlled Congress passed the Judiciary Act of 1801 in the final weeks of the Adams administration, creating 16 new circuit court judgeships and reducing the Supreme Court from six to five seats to prevent Jefferson from filling the next vacancy. The act also created dozens of justice of the peace positions in the District of Columbia. Jefferson called it a deliberate attempt to "intrench themselves in the strongholds of the judiciary" before the transfer of power — and it set up the constitutional confrontation that became Marbury v. Madison.