Martin v. Hunter's Lessee
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| Martin v. Hunter's Lessee | ||||||||||||
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| Argued March 12, 1816 Decided March 20, 1816 |
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| Article Three of the U.S. Constitution grants the U.S. Supreme Court jurisdiction and authority over state courts on matters involving federal law. | ||||||||||||
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| Chief Justice: John Marshall Associate Justices: Bushrod Washington, William Johnson, Henry Brockholst Livingston, Thomas Todd, Gabriel Duvall, Joseph Story |
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| Majority by: Story Joined by: Washington, Johnson, Livingston, Todd, Duvall Concurrence by: Johnson Marshall took no part in the consideration or decision of the case. |
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| U.S. Const. art. III | ||||||||||||
Martin v. Hunter's Lessee, , was a landmark United States Supreme Court case decided on March 20, 1816. It was the first case to assert ultimate Supreme Court authority over state courts in matters of federal law.
During the American Revolution, the state of Virginia enacted legislation that allowed it to confiscate Loyalists’ property. One such Loyalist named Denny Martin sued on the grounds that treaties with Great Britain guaranteed protection of Loyalist property. The Virginia state supreme court upheld the confiscation. It did not do so on the grounds that Virginia law was superior to U.S. treaties, but rather because it argued that its own interpretation of the treaty revealed that the treaty did not, in fact, cover the dispute. On review, the U.S. Supreme Court disagreed with this conclusion, ruling that the treaty did in fact cover the dispute, and remanded the case back to the Virginia Supreme Court, but the Virginia court then argued that the U.S. Supreme Court did not have authority over cases originating in state court. The U.S. Supreme Court reversed the state court’s decision on appeal, ruling that questions of federal law were within its jurisdiction, and thereby establishing its own supremacy in matters of constitutional interpretation.
Though Chief Justice John Marshall wrote most of the Supreme Court opinions during his tenure, he did not write this opinion. Marshall instead recused himself from the case for financial reasons because he and his brother had signed a contract with Martin to buy the land in dispute. Justice Joseph Story wrote the decision for a unanimous court.
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[edit] Opinion
Story first confronted the argument that Federal Judicial power came from the states, and therefore that the Supreme Court had no right to overrule a state's interpretation of the treaty without its consent. Story found that it was clear from history and the preamble of the Constitution that the Federal power was given directly by the people and not by the States. Story then found that Article III, Sec. 2, Cl. 2, stating that "in all other cases before mentioned the Supreme Court shall have appellate jurisdiction" showed a textual commitment to allow Supreme Court review of state decisions. If the Supreme Court could not review decisions from the highest State court, the State courts would be excluded from ever hearing a case in any way involving a Federal question, because the Supreme Court would be deprived of appellate jurisdiction in those cases. Thus, because it was established that the States had the power to rule on Federal issues it must be true that the Supreme Court can review the decision or the Supreme Court would not have appellate jurisdiction in "all other cases." Furthermore, the Supremacy Clause declares that the Federal interpretation will trump the States interpretation.
Story then quickly rejected concerns over State Judicial sovereignty. The Supreme court could already review state executive and legislative decisions and this case was no different. Story then confronted the arguments that State Judges were bound to uphold the Constitution just as Federal judges were, and so denying state interpretations presumed that the State Judges would less than faithfully interpret the Constitution. Story countered that even if State Judges were not biased, the issue was not bias but uniformity in Federal law. Furthermore, the legislative power to remove a case to Federal court would be inadequate for maintaining this uniformity. Finally, Story applied these principles of Judicial review to the decisions below and found that the state court's decision was in error.
[edit] See also
- Fairfax's Devisee v. Hunter's Lessee, 11 U.S. 603 (1813), predecessor to this case
- Cohens v. Virginia - related case (1821)
- List of United States Supreme Court cases, volume 14
- Jurisdiction stripping
[edit] References
- Jean Edward Smith, John Marshall: Definer Of A Nation, New York: Henry Holt & Company, 1996.
- Jean Edward Smith, The Constitution And American Foreign Policy, St. Paul, MN: West Publishing Company, 1989.
