The shay’s rebellion prompted leaders such as George Washington to call for a stronger national government that could suppress future rebellion. The Article of Confederation created a loose confederation of the sovereign states thus it was weak and it was supposed to undergo ratification. Chief Justice John Marshall of the U.S Supreme court first declared an act of Congress unconstitutional on 24/2/1803. This case was a foundation of the U.S constitutional law in that it started the establishment of the doctrine of judicial review.