It has often been said that judicial review is a necessary ingredient in a federated system, for supremacy must reside somewhere; and that in the American system, with its additional tripartite structure, it is an absolute necessity. Even critics of judicial review generally agree that the power of the Supreme Court over acts of state legislatures and state courts, as contradistinguished from its power over congressional legislation and presidential activities, is essential to the American political system and, in addition, is a constitutional directive (Article VI-the "supremacy clause").
Leonard B. Rosenberg,
Constitutional Supremacy: An Early Advocate of Judicial Review,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol7/iss4/2