held that state legislatures could determine the constitutionality of federal laws. In the 1800 presidential election, the Democratic-Republicans once again nominated a ticket of Jefferson and Burr. Shortly after a Federalist caucus re-nominated President Adams on a ticket with Charles Cotesworth Pinckney, Adams dismissed two Hamilton allies from his Cabinet, leading to an open break between the two key figures in the Federalist Party. Though the Federalist Party united against Jefferson's candidacy and waged an effective campaign in many states, the Democratic-Republicans won the election by winning most Southern electoral votes and carrying the crucial state of New York. A significant element in the party's success in New York City, Philadelphia, Baltimore and other east-coast cities were United Irish exiles, and other Irish immigrants, whom the Federalists regarded with distinct suspicion. Among these was William Duane who, in his paper the Philadelphia Aurora, exposed the details of the Ross Bill by the Federalist-controlled Congress sought to establish a closed-door Grand Committee with powers to disqualify College electors. Adams was to name Duane one of the three or four men most responsible for his eventual defeat. Jefferson and Burr both finished with 73 electoral votes, more than Adams or Pinckney, necessitating a contingent election between Jefferson and Burr in the House of Representatives. Burr declined to take his name out of consideration, and the House deadlocked as most Democratic-Republican congressmen voted for Jefferson and most Federalists voted for Burr. Preferring Jefferson to Burr, Hamilton helped engineer Jefferson's election on the 36th ballot of the contingent election. Jefferson would later describe the 1800 election, which also saw Democratic-Republicans gain control of Congress, as the "Revolution of 1800", writing that it was "as real of a revolution in the principles of our government as that of [1776] was in its form." In the final months of his presidency, Adams reached an agreement with France to end the Quasi-War and appointed several Federalist judges, including Chief Justice John Marshall. Jefferson's presidency, 1801–1809 Despite the intensity of the 1800 election, the transition of power from the Federalists to the Democratic-Republicans was peaceful. In his inaugural address, Jefferson indicated that he would seek to reverse many Federalist policies, but he also emphasized reconciliation, noting that "every difference of opinion is not a difference of principle". He appointed a geographically balanced and ideologically moderate Cabinet that included Madison as Secretary of State and Albert Gallatin as Secretary