Congress passed an act for a National Lottery to raise money for the District of Columbia. The state of Virginia passed a law prohibiting the sale of out-of-state lottery tickets, including National Lottery tickets. In 1820, Philip and Mendes Cohen of Virginia were charged by state authorities for selling tickets for the National Lottery in Virginia. The Supreme Court declared jurisdiction over this state court decision matter as it pertained to an act of Congress, thus reaffirming judicial review. Thus, the Supreme Court ruled against the Cohens because the act of Congress did not aim to sell tickets outside of the District of Columbia, and therefore, Virginia acted constitutionally to prohibit such sales within its borders.