Although The Federalist was not reliably distributed outside of New York, the essays eventually became the dominant reference for interpreting the meaning of the Constitution as they provided the reasoning and justification behind the Framers' intent in setting up the federal government. While Hamilton's view prevailed during the administrations of Presidents Washington and Adams, historians argue that his view of the General Welfare Clause was repudiated in the election of 1800, and helped establish the primacy of the Democratic-Republican Party for the subsequent 24 years. This assertion is based on the motivating factor which the Kentucky and Virginia Resolutions played upon the electorate; the Kentucky Resolutions, authored by Thomas Jefferson, specifically criticized Hamilton's view. Further, Jefferson himself later described the distinction between the parties over this view as "almost the only landmark which now divides the federalists from the republicans...." Associate Justice Joseph Story relied heavily upon The Federalist as a source for his Commentaries on the Constitution of the United States. In that work, Story excoriated both the Madisonian view and a previous, strongly nationalistic view of Hamilton's which was rejected at the Philadelphia Convention. Ultimately, Story concluded that Thomas Jefferson's view of the clause as a limitation on the power to tax, given in Jefferson's opinion to Washington on the constitutionality of the national bank, was the correct reading. However, Story also concluded that Hamilton's view on spending, articulated in his 1791 Report on Manufactures, is the correct reading of the spending power. Prior to 1936, the United States Supreme Court had imposed a narrow interpretation of the Clause, as demonstrated by the holding in Bailey v. Drexel Furniture Co., (1922) in which a tax on child labor was an impermissible attempt to regulate commerce beyond that Court's equally narrow interpretation of the Commerce Clause. This narrow view was overturned in 1936 in United States v. Butler. There, the Court agreed with Justice Story's construction, holding the power to tax and spend is an independent power; that is, the General Welfare Clause gives Congress power it might not derive anywhere else. However, the Court did limit the power to spending for matters affecting only the national welfare. The Court wrote: The tax imposed in Butler was nevertheless held unconstitutional as a violation of the Tenth Amendment reservation of power to the states. Shortly after Butler, in Helvering v. Davis, the Supreme Court interpreted the clause even more expansively,