acknowledging the freedom of the press, nevertheless sentenced Oswald to one month in jail and a £10 fine. On 19 April 1809, Respublica v. Passmore limited the power of courts to issue summary contempts such as the one used against Oswald. In the summer of 1787, during and immediately after the Constitutional Convention, Oswald printed articles in support of ratification. After the convention concluded, however, Oswald began publishing pieces critical of the proposed constitution. The Independent Gazetteer was one of only twelve papers in the United States to regularly publish essays opposing ratification. Between 5 October 1787 and 24 November 1788 a series of 24 anti-Federalist articles were published in the Independent Gazetteer and Freeman's Journal in Philadelphia. Written by Centinel the Letters of Centinel argued against adopting the United States Constitution. It is believed that Samuel Bryan wrote most of the articles, but that Oswald may have penned a few of them. Oswald moved to New York City and published the Independent Gazette, or New York Journal Revived. This was the journal that his father-in-law started. He came out against Alexander Hamilton in print and a duel between the two was narrowly averted by friends. In 1792 he traveled first to England, then France. On 18 September 1792, Oswald received a colonel's commission in the French army from General Charles François Dumouriez. He fought at the Battle of Jemappes on 6 November 1792 where he had command of four of the 24 artillery units. Historian Digby Smith noted that most of the Austrian casualties in the action were inflicted by cannon fire. In a subsequent action at Liège, Oswald commanded 12 of the 24 units. On 16 January 1793 he left the army in Belgium to go on a secret mission for the French government. From 20 February to 8 June 1793 he was employed in Ireland where he reported on dissatisfaction with the British government. Being American, he was able to go about his espionage activities without causing suspicion. A remarkable set of documents survived in which Oswald sought reimbursement from the French government for expenses he incurred in the line of duty. On 11 and 23 July 1793 he sent the requests to the Minister of War Jean Baptiste Noël Bouchotte. His secret mission was certified by the Minister of Foreign Affairs Pierre Henri Hélène Marie Lebrun-Tondu. A letter of introduction from Thomas Paine testified that Oswald's