 Just as civic eloquence failed to gain popularity in Britain, in the United States interest faded in the second decade of the 19th century, as the "public spheres of heated oratory" disappeared in favor of the private sphere.After resigning from the Senate, Adams was ostracized by Massachusetts Federalist leaders, but he declined Democratic-Republican entreaties to seek office.In 1809, he argued before the Supreme Court of the United States in the case of "Fletcher v. Peck", and the Supreme Court ultimately agreed with Adams's argument that the Constitution's Contract Clause prevented the state of Georgia from invalidating a land sale to out-of-state companies.