without any mention at all of  Hamilton’s strange claim that liberty of the press is undefinable.[193]

Hamilton’s argument in the Federalist Papers seems to show that, by the end of the ratification controversy, even Federalist leaders who did not think seditious libel prosecutions violated press freedom were avoiding that position. The anti-Federalists had made their point: a free press guarantee was needed to protect people against prosecution by the federal government for libels.  This was one of several issues that anti-Federalists hammered away at.  But it was an issue that received much attention during the debate.  Ultimately, ratification of the constitution could only be achieved in states such as Massachusetts, New York, Maryland and Virginia, based on a compromise that involved a Federalist promise to add a bill of rights after ratification including press freedom. [194]

[193] Emergence at 225.

[194] The promise involved several states adding recommended amendments, which included several versions of a free press guarantee.  Emergence at 253