"Judicial Review" (invalidating) of acts of Congress is fine when Congress does something that goes outside the bounds established for it by the Constitution. It is not so good when it goes to invalidating nearly all of the Bill of Rights which is something Marshall did when he ruled that the Bill of Rights prohibitions outside of the first amendment prohibitions which were specifically limited to the Federal Government, were also limited to the Federal Government.
ML/NJ
The initial intent of the survey was to evaluate the Americans who have had the greatest impact on the country. I agree, Marshall was not necessarily a positive influence, but no one can doubt his overall importance to the system as it stands.