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''Martin v. Hunter's Lessee'', 14 U.S. (1 Wheat.) 304 (1816), was a
landmark decision Landmark court decisions, in present-day common law legal systems, establish precedents that determine a significant new legal principle or concept, or otherwise substantially affect the interpretation of existing law. "Leading case" is commonly ...
of the
Supreme Court of the United States The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. Federal tribunals in the United States, federal court cases, and over Stat ...
decided on March 20, 1816. It was the first case to assert ultimate Supreme Court
authority In the fields of sociology and political science, authority is the legitimate power of a person or group over other people. In a civil state, ''authority'' is practiced in ways such a judicial branch or an executive branch of government.''T ...
over state courts in civil matters of
federal law Federal law is the body of law created by the federal government of a country. A federal government is formed when a group of political units, such as states or provinces join in a federation, delegating their individual sovereignty and many ...
.


Facts

During the
American Revolution The American Revolution was an ideological and political revolution that occurred in British America between 1765 and 1791. The Americans in the Thirteen Colonies formed independent states that defeated the British in the American Revoluti ...
, the
Commonwealth A commonwealth is a traditional English term for a political community founded for the common good. Historically, it has been synonymous with "republic". The noun "commonwealth", meaning "public welfare, general good or advantage", dates from the ...
of
Virginia Virginia, officially the Commonwealth of Virginia, is a state in the Mid-Atlantic and Southeastern regions of the United States, between the Atlantic Coast and the Appalachian Mountains. The geography and climate of the Commonwealth are ...
enacted
legislation Legislation is the process or result of enrolling, enacting, or promulgating laws by a legislature, parliament, or analogous governing body. Before an item of legislation becomes law it may be known as a bill, and may be broadly referred to ...
that allowed it to confiscate
Loyalist Loyalism, in the United Kingdom, its overseas territories and its former colonies, refers to the allegiance to the British crown or the United Kingdom. In North America, the most common usage of the term refers to loyalty to the British C ...
s'
property Property is a system of rights that gives people legal control of valuable things, and also refers to the valuable things themselves. Depending on the nature of the property, an owner of property may have the right to consume, alter, share, r ...
. Land owned by a loyalist, Martin, part of the Northern Neck Property, was confiscated by the State and transferred to David Hunter. The
Treaty of Paris (1783) The Treaty of Paris, signed in Paris by representatives of King George III of Great Britain and representatives of the United States of America on September 3, 1783, officially ended the American Revolutionary War and overall state of conflict ...
between Great Britain and the United States nullified such confiscations, permitting Martin to sue for the return of the property. The trial court ruled in his favor, but the
Virginia Supreme Court The Supreme Court of Virginia is the highest court in the Commonwealth of Virginia. It primarily hears direct appeals in civil cases from the trial-level city and county circuit courts, as well as the criminal law, family law and administrativ ...
upheld the
confiscation Confiscation (from the Latin ''confiscatio'' "to consign to the ''fiscus'', i.e. transfer to the treasury") is a legal form of seizure by a government or other public authority. The word is also used, popularly, of spoliation under legal forms, ...
. The court did not rule that Virginia law was superior to U.S. treaties, but held that the treaty did not cover the dispute in question. On review in '' Fairfax's Devisee v. Hunter's Lessee'',The reference to Hunter's lessee is due to a technicality in actions of
ejectment Ejectment is a common law term for civil action to recover the possession of or title to land. It replaced the old real actions and the various possessory assizes (denoting county-based pleas to local sittings of the courts) where boundary dis ...
.
11 U.S. 603 (1813), 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. The Virginia court in turn decided that the U.S. Supreme Court did not have authority over cases originating in state court:
The Court is unanimously of opinion, that the appellate power of the Supreme Court of the United States does not extend to this Court, under a sound construction of the Constitution of the United States; that so much of the 25th section of the act of Congress to establish the judicial courts of the United States, as extends the appellate jurisdiction of the Supreme Court to this Court, is not in pursuance of the Constitution of the United States; that the writ of error in this cause was improvidently allowed under the authority of that act; that the proceedings thereon in the Supreme Court were coram non judice in relation to this Court, and that obedience to its mandate be declined by the Court.
The U.S. Supreme Court reversed the state court's decision on
appeal In law, an appeal is the process in which cases are reviewed by a higher authority, where parties request a formal change to an official decision. Appeals function both as a process for error correction as well as a process of clarifying and ...
, ruling that questions of federal law were within its
jurisdiction Jurisdiction (from Latin 'law' + 'declaration') is the legal term for the legal authority granted to a legal entity to enact justice. In federations like the United States, areas of jurisdiction apply to local, state, and federal levels. J ...
, and thereby establishing its own supremacy in matters of
constitution A constitution is the aggregate of fundamental principles or established precedents that constitute the legal basis of a polity, organisation or other type of entity and commonly determine how that entity is to be governed. When these pr ...
al interpretation. Though Chief Justice
John Marshall John Marshall (September 24, 1755July 6, 1835) was an American politician and lawyer who served as the fourth Chief Justice of the United States from 1801 until his death in 1835. He remains the longest-serving chief justice and fourth-longes ...
wrote most of the Supreme Court opinions during his tenure, he did not write this opinion. Marshall instead
recused Judicial disqualification, also referred to as recusal, is the act of abstaining from participation in an official action such as a legal proceeding due to a conflict of interest of the presiding court official or administrative officer. Appli ...
himself, citing a
conflict of interest A conflict of interest (COI) is a situation in which a person or organization is involved in multiple interests, financial or otherwise, and serving one interest could involve working against another. Typically, this relates to situations i ...
due to his relatives' interest in the property. Justice
Joseph Story Joseph Story (September 18, 1779 – September 10, 1845) was an associate justice of the Supreme Court of the United States, serving from 1812 to 1845. He is most remembered for his opinions in ''Martin v. Hunter's Lessee'' and '' United States ...
wrote the decision for a unanimous court.


Judgment

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 cited Article III, Section 2, Clause 2, showing a textual commitment to allow Supreme Court
judicial review Judicial review is a process under which executive, legislative and administrative actions are subject to review by the judiciary. A court with authority for judicial review may invalidate laws, acts and governmental actions that are incomp ...
of state decisions: If the Supreme Court could not review the decisions of the highest state court, state courts would be excluded from ever hearing a case involving a
federal question In United States law, federal question jurisdiction is a type of subject-matter jurisdiction that gives United States federal courts the power to hear civil cases where the plaintiff alleges a violation of the United States Constitution, federa ...
. 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" as stated by the Constitution. Furthermore, the
Supremacy Clause The Supremacy Clause of the Constitution of the United States ( Article VI, Clause 2) establishes that the Constitution, federal laws made pursuant to it, and treaties made under its authority, constitute the "supreme Law of the Land", and thu ...
declares that federal interpretation trumps the state's interpretation. Story rejected concerns over State judicial sovereignty. Under Article I, Section 10 of the Constitution specific limits are placed upon the "sovereignty" of state governments. The Supreme Court could already review state executive and legislative decisions and this case was no different. Story then confronted the argument 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 Judicial review is a process under which executive, legislative and administrative actions are subject to review by the judiciary. A court with authority for judicial review may invalidate laws, acts and governmental actions that are incomp ...
to the decisions below and found that the state court's decision was in error. Story said the following in his judgment: The vote tally was 6 to 0, with
Johnson Johnson is a surname of Anglo-Norman origin meaning "Son of John". It is the second most common in the United States and 154th most common in the world. As a common family name in Scotland, Johnson is occasionally a variation of ''Johnston'', a ...
giving a concurring opinion.


See also

* ''
Cohens v. Virginia ''Cohens v. Virginia'', 19 U.S. (6 Wheat.) 264 (1821), is a landmark case by the Supreme Court of the United States that is most notable for the Court's assertion of its power to review state supreme court decisions in criminal law matters if def ...
,'' (a parallel case raising the issue of federal judicial review of state criminal, as opposed to civil, matters) * ''
Barron v. Baltimore ''Barron v. Baltimore'', 32 U.S. (7 Pet.) 243 (1833), is a landmark United States Supreme Court case in 1833, which helped define the concept of federalism in US constitutional law. The Court ruled that the Bill of Rights did not apply to the stat ...
'' (1833) *
List of United States Supreme Court cases, volume 14 This is a list of cases reported in volume 14 (1 Wheat.) of ''United States Reports'', decided by the Supreme Court of the United States in 1816. Nominative reports In 1874, the U.S. government created the ''United States Reports'', and re ...
*
Jurisdiction stripping In United States law, jurisdiction-stripping (also called court-stripping or curtailment-of-jurisdiction), is the limiting or reducing of a court's jurisdiction by Congress through its constitutional authority to determine the jurisdiction of f ...
*
Treaty of Paris (1783) The Treaty of Paris, signed in Paris by representatives of King George III of Great Britain and representatives of the United States of America on September 3, 1783, officially ended the American Revolutionary War and overall state of conflict ...
*
Jay Treaty The Treaty of Amity, Commerce, and Navigation, Between His Britannic Majesty and the United States of America, commonly known as the Jay Treaty, and also as Jay's Treaty, was a 1794 treaty between the United States and Great Britain that averted ...


References

*F. Thornton Miller, "John Marshall Versus Spencer Roane: A Reevaluation of ''Martin'' v. ''Hunter's Lessee''," ''Virginia Magazine of History and Biography'' 96 (July 1988): 297-314. * 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.


External links

* *
Case Brief for Martin v. Hunter's Lessee at Lawnix.com
{{USArticleIII United States Constitution Article Three case law United States Supreme Court cases of the Marshall Court 1816 in United States case law United States federalism case law Legal history of Virginia Northern Neck Virginia in the American Revolution United States Supreme Court cases