The Schooner Rachel v. The United States was a landmark Supreme Court case that established the principle of judicial review in the United States. In this case, French citizen Jean de la Corne had purchased a schooner named Rachel from an American merchant and set sail for France with it. However, during its voyage, the ship was stopped by an American warship and seized on suspicion of smuggling goods to France in violation of President Thomas Jefferson's embargo against Britain and France. De la Corne sued for replevin (the return of his property) but lost at trial because he could not prove ownership due to lack of documentation proving his purchase from the original owner. On appeal to the Supreme Court, Chief Justice John Marshall ruled that although there may have been no evidence presented at trial establishing de la Corne's ownership over Rachel, since Congress had passed legislation authorizing seizure without proof or process as part of enforcing Jefferson’s embargo policy; such action violated Article III Section 2 Clause 2 which grants federal courts jurisdiction over cases involving foreign citizens like de La Corne who are suing states or their officers under U.S law - thus making it unconstitutional according to Marshall’s ruling . This decision marked one of first times where a court declared an act by Congress unconstitutional – setting precedent for future rulings on judicial review throughout US history

In The Schooner Rachel v. The United States, the Supreme Court was asked to decide whether a French vessel seized by an American privateer during the Quasi-War with France could be legally condemned as a prize of war. Chief Justice Marshall wrote for the majority that it could not because there had been no formal declaration of war between France and America at the time of seizure, so Congress had not authorized such seizures under its power to declare war. However, in his dissenting opinion Justice Johnson argued that although there may have been no formal declaration of war between France and America at this time, hostilities were taking place which justified treating these vessels as prizes according to international law principles. He further argued that since Congress had authorized naval forces against French ships on June 18th 1798 (prior to this incident) they must have intended their authorization to include capturing enemy vessels even without a formal declaration of war being made first.