The "New York Herald" wrote that the Supreme Court “by a bare majority of one holds that the constitution is supreme only in the States, and that a million square miles, or one-fourth of the national domain, and ten million people are subject to no law but the will of Congress…” Furthermore, the Denver Post exclaimed the "Downes decision 'at one fell swoop' brought the United States 'into the ownership of colonies and putting us into the rank of land grabbing nations of Europe."