The Judiciary Act of 1801 was passed by a lame duck Federalist Congress.

Name: The Judiciary Act of 1801 was passed by a lame duck Federalist Congress.
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The Judiciary Act of 1801 was passed by a Federalist-controlled Congress in the final days of John Adams' presidency, after the Democratic-Republicans had won the 1800 election but before Thomas Jefferson took office. This is commonly referred to as a "lame duck" Congress.

The Judiciary Act of 1801 Was Passed by a Lame