"Hamilton’s death was particularly painful to a Federalist newspaper editor, Harry Croswell, who was charged and eventually convicted of seditiously libeling President Jefferson by New York’s Jeffersonian attorney general Ambrose Spencer. Spencer shared his party leader’s belief that regulation of the press was an appropriate action for state governments. In a letter to the governor of Pennsylvania, President Jefferson had encouraged “a few prosecutions” that “would have a wholesome effect in restoring the integrity of the presses.” In one of his last legal cases before his death, Hamilton handled Croswell’s appeal of his conviction before the New York Supreme Court in 1804. Hamilton’s argument failed to overturn Croswell’s conviction, but it was instrumental in convincing the New York state legislature, and many others, to allow for the truthfulness of an allegation to be admitted in evidence in a criminal libel suit. While frequently portrayed in our time and in the early years of the Republic as an enemy of a free press, Hamilton’s role in the Croswell case belied his critics’ stereotype. Hearing of Hamilton’s death, Croswell wrote, “To me he once rendered unequalled service…in my defence, and in defence of the American press…. For this service, voluntarily rendered, I owed him a debt of gratitude which never could be cancelled."
— Stephen Knott, Alexander Hamilton and the Persistence of Myth (via publius-esquire)