In the Thirteen Colonies, there were instances of Coke's statement being interpreted to mean that the common law was superior to statute. For example, drawing on Coke's statement, James Otis, Jr., declared during the struggle over writs of assistance courts had to ignore Acts of Parliament "against the constitution and against natural equity", which had a significant impact on John Adams. When the 1765 Stamp Act was declared invalid by the Massachusetts Assembly, the rationale was that it was "against Magna Charta and the natural rights of Englishmen, and therefore, according to the Lord Coke, null and void". By 1772, Otis and others had reversed course by adopting Blackstone's position that judges cannot challenge Acts of Parliament. Even before then, "Dr. Bonham's Case" had rarely been used as a rallying cry in America; judicial review in America grew primarily from other political and intellectual sources.