Throughout the nineteenth century the U.S. Supreme Court had little direct involvement in the administration of military or naval forces. However, as the ultimate authority on international law in the United States, and as an appellate court dealing with property issues decided either in the subordinate federal courts or in the highest courts of the states having jurisdiction, the Court had a small but measurable impact on military policy. Before John Marshall became chief justice in 1801, the small number of litigated cases and the lack of extensive international warfare prior to 1797 limited the Court's influence in military and naval affairs. However, the outbreak of the quasi-war with France (1798–1800) directed the justices' attention to military matters. Eventually, the American law of warfare would become a point of major concern and a great deal of disagreement, as complex legal and constitutional...