Although the Court's opinion in "Marbury" established judicial review in American federal law, it did not create or invent it. Some 18th-century British jurists had argued that British courts had the power to circumscribe Parliament, and the principle became generally accepted in Colonial Americaespecially in Marshall's native Virginiadue to the idea that in America only the people were sovereign, rather than the government, and therefore that the courts should only implement legitimate laws. By the time of the Constitutional Convention in 1787, American courts' "independent power and duty to interpret the law" was well established, and Alexander Hamilton defended the concept of judicial review in "Federalist No. 78." Nevertheless, Marshall's opinion in "Marbury" was the power's first announcement and exercise by the Supreme Court. It made the practice more routine, rather than exceptional, and prepared the way for the Court's opinion in the 1819 case "McCulloch v. Maryland", in which Marshall implied that the Supreme Court was the supreme interpreter of the U.S. Constitution.