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Following the American Revolutionary War, when the Thirteen Colonies formed the United States of America, war hero and Virginian George Washington was the choice to become its first president. Washington had been a surveyor and developer of canals for transportation earlier in the 18th century. He was also a great proponent of the bustling port city of Alexandria, which was located on the Potomac River below the fall line, not far from his plantation at Mount Vernon in Fairfax County. With his guidance, a new federal city (now known as the District of Columbia) was laid out straddling the Potomac River upon a square of territory which was ceded to the federal government by the new states of Maryland and Virginia. Alexandria was located at the eastern edge south of the river. On the outskirts on the northern side of the river, another port city, Georgetown, was located. However, as the federal city grew, land in the portion contributed by Maryland proved best suited and adequate for early development and the impracticality of being on both sides of the Potomac River became clearer. Not really part of the functioning federal city, many citizens of Alexandria were frustrated by the laws of the District government and lack of voting input. Slavery also arose as an issue. To mitigate these issues, and as part of a "deal" regarding abolishment of slave trading in the District, in 1846, the U.S. Congress passed a bill retro-ceding to Virginia the area south of the Potomac River, which was known as Alexandria County. That area now forms all of Arlington County (which was renamed from Alexandria County in 1922) and a portion of the independent city of Alexandria. Slavery, states rights, and economic issues increasingly divided the northern and southern states during the first half of the 19th century, eventually leading to the American Civil War from 1861–1865. Although Maryland was a slave state, it remained with the Union, while Virginia seceded and joined the newly formed Confederate States of America, with its new capital established at Richmond, Virginia. The Supreme Court of the United States has never issued a firm opinion on whether the retrocession of the Virginia portion of the District of Columbia was constitutional. In the 1875 case of Phillips v. Payne, the Supreme Court held that Virginia had de facto jurisdiction over the area returned by Congress in 1847, and dismissed the tax case brought by the plaintiff. The court, however, did not rule on the core constitutional matter of the retrocession. Writing the majority opinion, Justice Noah Swayne stated only that:
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