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''Martin v. Hunter's Lessee'', 14 U.S. (1 Wheat.) 304 (1816), was a landmark decision 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 Federal tribunals in the United States, U.S. federal court cases, and over Stat ...
decided on March 20, 1816. It was the first case to assert ultimate Supreme Court
authority Authority is commonly understood as the legitimate power of a person or group of other people. In a civil state, ''authority'' may be practiced by legislative, executive, and judicial branches of government,''The New Fontana Dictionary of M ...
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 country has a central government as well as regional governments, such as subnational states or provinces, each with constituti ...
. Though Chief Justice
John Marshall John Marshall (September 24, 1755July 6, 1835) was an American statesman, jurist, and Founding Fathers of the United States, Founding Father who served as the fourth chief justice of the United States from 1801 until his death in 1835. He remai ...
wrote most of the Supreme Court opinions during his tenure, he did not write this opinion. Marshall instead recused himself, citing a
conflict of interest A conflict of interest (COI) is a situation in which a person or organization is involved in multiple wikt:interest#Noun, interests, financial or otherwise, and serving one interest could involve working against another. Typically, this relates t ...
due to his relatives' interest in the property. Justice
Joseph Story Joseph Story (September18, 1779September10, 1845) was an American lawyer, jurist, and politician who served as an associate justice of the Supreme Court of the United States from 1812 to 1845. He is most remembered for his opinions in ''Martin ...
wrote the decision for a unanimous court.


Facts

During the
American Revolution The American Revolution (1765–1783) was a colonial rebellion and war of independence in which the Thirteen Colonies broke from British America, British rule to form the United States of America. The revolution culminated in the American ...
, the Commonwealth of
Virginia Virginia, officially the Commonwealth of Virginia, is a U.S. state, state in the Southeastern United States, Southeastern and Mid-Atlantic (United States), Mid-Atlantic regions of the United States between the East Coast of the United States ...
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 ...
that allowed it to confiscate Loyalists'
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, re ...
. 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 Kingdom of Great Britain, Great Britain and representatives of the United States on September 3, 1783, officially ended the American Revolutionary War and recognized ...
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 upheld the
confiscation Confiscation (from the Latin ''confiscatio'' "to consign to the ''fiscus'', i.e. transfer to the treasury") is a legal form of search and seizure, seizure by a government or other public authority. The word is also used, popularly, of Tampering w ...
. 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 dispu ...
.
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 Legal case, 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 cla ...
, ruling that questions of federal law were within its
jurisdiction Jurisdiction (from Latin 'law' and 'speech' or 'declaration') is the legal term for the legal authority granted to a legal entity to enact justice. In federations like the United States, the concept of jurisdiction applies at multiple level ...
, 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, organization or other type of entity, and commonly determines how that entity is to be governed. When these pri ...
al interpretation. Though Chief Justice
John Marshall John Marshall (September 24, 1755July 6, 1835) was an American statesman, jurist, and Founding Fathers of the United States, Founding Father who served as the fourth chief justice of the United States from 1801 until his death in 1835. He remai ...
wrote most of the Supreme Court opinions during his tenure, he did not write this opinion. Marshall instead recused himself, citing a
conflict of interest A conflict of interest (COI) is a situation in which a person or organization is involved in multiple wikt:interest#Noun, interests, financial or otherwise, and serving one interest could involve working against another. Typically, this relates t ...
due to his relatives' interest in the property. Justice
Joseph Story Joseph Story (September18, 1779September10, 1845) was an American lawyer, jurist, and politician who served as an associate justice of the Supreme Court of the United States from 1812 to 1845. He is most remembered for his opinions in ''Martin ...
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 a government's executive, legislative, or administrative actions are subject to review by the judiciary. In a judicial review, a court may invalidate laws, acts, or governmental actions that are in ...
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. 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 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 a government's executive, legislative, or administrative actions are subject to review by the judiciary. In a judicial review, a court may invalidate laws, acts, or governmental actions that are in ...
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 giving a concurring opinion.


See also

* '' Cohens v. Virginia,'' (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 List of landmark court decisions in the United States, landmark Supreme Court of the United States, United States Supreme Court case in 1833, which helped define the concept of federalism ...
'' (1833) * List of United States Supreme Court cases, volume 14 * Jurisdiction stripping *
Treaty of Paris (1783) The Treaty of Paris, signed in Paris by representatives of King George III of Kingdom of Great Britain, Great Britain and representatives of the United States on September 3, 1783, officially ended the American Revolutionary War and recognized ...
*
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