unconstitutional<ref name="Crosskey">See W.W. Crosskey, Politics and the Constitution in the History of the United States (Chicago: 1953), chs. 27–29, with which compare Hart, Book Review, 67 Harv. L. Rev. 1456 (1954). A brief review of the debate on the subject is Westin, "Introduction: Charles Beard and American Debate over Judicial Review, 1790–1961", in: C. Beard, The Supreme Court and the Constitution (Englewood Cliffs: 1962 reissue of 1938 ed.), 1–34, and bibliography at 133–149. See more at: http://constitution.findlaw.com/article3/annotation13.html#f576</ref> based on two arguments. First, the power of judicial review is not expressly delegated to the federal courts in the Constitution. The Tenth Amendment reserves to the states (or to the people) those powers not expressly delegated to the federal government. The second argument is that the states alone have the power to ratify changes to the "supreme law" (the U.S. Constitution), and each state's understanding of the language of the amendment therefore becomes germane to its implementation and effect, making it necessary that the states play some role in interpreting its meaning. Under this theory, allowing only federal courts to definitively conduct judicial review of federal law allows the national government to interpret its own restrictions as it sees fit, with no meaningful input from the ratifying, that is, validating power. Standard of review In the United States, unconstitutionality is the only ground for a federal court to strike down a federal statute. Justice Washington, speaking for the Marshall Court, put it this way in an 1829 case: If a state statute conflicts with a valid federal statute, then courts may strike down the state statute as an unstatutable violation of the Supremacy Clause. But a federal court may not strike down a statute absent a violation of federal law or of the federal Constitution. Moreover, a suspicion or possibility of unconstitutionality is not enough for American courts to strike down a statute. Alexander Hamilton explained in Federalist 78 that the standard of review should be "irreconcilable variance" with the Constitution. Anti-federalists agreed that courts would be unable to strike down federal statutes absent a conflict with the Constitution. For example, Robert Yates, writing under the pseudonym "Brutus", asserted that "the courts of the general government [will] be under obligation to observe the laws made by the general legislature not repugnant to the constitution." These principles—that federal statutes can only be struck down for unconstitutionality and that the unconstitutionality must be clear—were