Following the ratification of the first amendment, congress passed the Sedition Act of 1798, which punished those who spoke out against the government and was later declared unconstitutional.
This act targets the editors of Democratic-Republican newspapers who use to criticize the federalist administration of President John Adams.
Lyon claimed the Sedition Act was illegal because states had jurisdiction over libel laws.
It is so because this act made it a crime for American citizens to "print, utter, or publish any scandalous, false and malicious writings" about the government. The purpose of this act was to give the government the power/authority to imprison/deport foreign citizens and prosecute critics of the government.
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