In defending Zenger in this landmark case, Hamilton and Smith attempted to establish the precedent that a statement, even if defamatory, is not libelous if it can be proved, thus affirming freedom of the press in America; however, succeeding royal governors clamped down on freedom of the press until the American Revolution. This case is the groundwork of freedom of the press, not its legal precedent. As late as 1804, the journalist Harry Croswell lost a series of prosecutions and appeals because truth was "not" a defense against libel, as decided by the New York Supreme Court in "People v. Croswell". It was only the following year that the assembly, reacting to this verdict, passed a law that allowed truth as a defense against a charge of libel.