Martin v. Hunter's Lessee
Encyclopedia
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
.
, the state
of Virginia
enacted legislation
that allowed it to confiscate Loyalist
s' property
. Here, the original suit was an action of ejectment
brought in Virginia state court for the recovery of land in the state known as the Northern Neck Proprietary. A declaration in ejectment was served in April, 1791 on the tenants in possession of the land. Denny Fairfax (late Denny Martin) was a British
subject who held the land under the devise of Lord Thomas Fairfax
. Denny Martin was admitted to defend the suit and plead the general issue upon the usual terms of confessing lease, entry, and ouster. Martin agreed to assert only claim to the title. The facts being settled in the form of a case agreed to be taken and considered as a special verdict, the court, on consideration thereof, gave judgment in favor of the defendant in ejectment on April 24, 1794. From that judgment the plaintiff in ejectment (now defendant in error) appealed to the court of appeals.
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 in Fairfax's Devisee v. Hunter's Lessee
, 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, 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 constitution
al 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, citing a financial conflict of interest
; he and his brother James had signed a contract with Martin to buy the land in dispute. Justice Joseph Story
wrote the decision for a unanimous court.
declares that the Federal interpretation will trump the State's 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.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case decided on March 20, 1816. It was the first case to assert ultimate Supreme Court authority
Authority
The word Authority is derived mainly from the Latin word auctoritas, meaning invention, advice, opinion, influence, or command. In English, the word 'authority' can be used to mean power given by the state or by academic knowledge of an area .-Authority in Philosophy:In...
over state courts in matters of federal law
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 together in a federation, surrendering their individual sovereignty and many powers to the central government while...
.
Background
During the American RevolutionAmerican Revolution
The American Revolution was the political upheaval during the last half of the 18th century in which thirteen colonies in North America joined together to break free from the British Empire, combining to become the United States of America...
, the state
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...
of Virginia
Virginia
The Commonwealth of Virginia , is a U.S. state on the Atlantic Coast of the Southern United States. Virginia is nicknamed the "Old Dominion" and sometimes the "Mother of Presidents" after the eight U.S. presidents born there...
enacted legislation
Legislation
Legislation is law which has been promulgated by a legislature or other governing body, or the process of making it...
that allowed it to confiscate Loyalist
Loyalist (American Revolution)
Loyalists were American colonists who remained loyal to the Kingdom of Great Britain during the American Revolutionary War. At the time they were often called Tories, Royalists, or King's Men. They were opposed by the Patriots, those who supported the revolution...
s' property
Property
Property is any physical or intangible entity that is owned by a person or jointly by a group of people or a legal entity like a corporation...
. Here, the original suit was an action of ejectment
Ejectment
Ejectment is the common law term for civil action to recover the possession of and title to land. It replaced the old real actions as well as the various possessory assizes...
brought in Virginia state court for the recovery of land in the state known as the Northern Neck Proprietary. A declaration in ejectment was served in April, 1791 on the tenants in possession of the land. Denny Fairfax (late Denny Martin) was a British
United Kingdom
The United Kingdom of Great Britain and Northern IrelandIn the United Kingdom and Dependencies, other languages have been officially recognised as legitimate autochthonous languages under the European Charter for Regional or Minority Languages...
subject who held the land under the devise of Lord Thomas Fairfax
Thomas Fairfax, 6th Lord Fairfax of Cameron
Thomas Fairfax, 6th Lord Fairfax of Cameron was the son of Thomas Fairfax, 5th Lord Fairfax of Cameron and of Catherine, daughter of Thomas Culpeper, 2nd Baron Culpeper of Thoresway....
. Denny Martin was admitted to defend the suit and plead the general issue upon the usual terms of confessing lease, entry, and ouster. Martin agreed to assert only claim to the title. The facts being settled in the form of a case agreed to be taken and considered as a special verdict, the court, on consideration thereof, gave judgment in favor of the defendant in ejectment on April 24, 1794. From that judgment the plaintiff in ejectment (now defendant in error) appealed to the court of appeals.
The Virginia state supreme court
State supreme court
In the United States, the state supreme court is the highest state court in the state court system ....
upheld the confiscation
Confiscation
Confiscation, from the Latin confiscatio 'joining to the fiscus, i.e. transfer to the treasury' is a legal seizure without compensation by a government or other public authority...
. 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 in Fairfax's Devisee v. Hunter's Lessee
Fairfax's Devisee v. Hunter's Lessee
Fairfax's Devisee v. Hunter's Lessee, 11 U.S. 603 , was a United States Supreme Court case arising out of the acquisition of Fairfax land in the Northern Neck of the state of Virginia by the family and associates of John Marshall, including Robert Morris...
, 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, but the Virginia court then argued 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 judiceCoram non judiceCoram non judice, Latin for "before one who is not a judge," is a legal term typically used to indicate a legal proceeding without a judge, with improper venue, or without jurisdiction....
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
Appeal
An appeal is a petition for review of a case that has been decided by a court of law. The petition is made to a higher court for the purpose of overturning the lower court's decision....
, ruling that questions of federal law were within its jurisdiction
Jurisdiction
Jurisdiction is the practical authority granted to a formally constituted legal body or to a political leader to deal with and make pronouncements on legal matters and, by implication, to administer justice within a defined area of responsibility...
, and thereby establishing its own supremacy in matters of constitution
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
al interpretation.
Though Chief Justice John Marshall
John Marshall
John Marshall was the Chief Justice of the United States whose court opinions helped lay the basis for American constitutional law and made the Supreme Court of the United States a coequal branch of government along with the legislative and executive branches...
wrote most of the Supreme Court opinions during his tenure, he did not write this opinion. Marshall instead recused himself, citing a financial conflict of interest
Conflict of interest
A conflict of interest occurs when an individual or organization is involved in multiple interests, one of which could possibly corrupt the motivation for an act in the other....
; he and his brother James had signed a contract with Martin to buy the land in dispute. Justice Joseph Story
Joseph Story
Joseph Story was an American lawyer and jurist who served on the Supreme Court of the United States from 1811 to 1845. He is most remembered today for his opinions in Martin v. Hunter's Lessee and The Amistad, along with his magisterial Commentaries on the Constitution of the United States, first...
wrote the decision for a unanimous court.
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 cited 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 ClauseSupremacy Clause
Article VI, Clause 2 of the United States Constitution, known as the Supremacy Clause, establishes the U.S. Constitution, U.S. Treaties, and Federal Statutes as "the supreme law of the land." The text decrees these to be the highest form of law in the U.S...
declares that the Federal interpretation will trump the State's 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.
See also
- List of United States Supreme Court cases, volume 14
- Jurisdiction strippingJurisdiction strippingJurisdiction stripping, also called curtailment of jurisdiction or court stripping, refers to the congressional practice of defining the jurisdiction of the United States federal judiciary as to eliminate its ability to hear certain classes of claims, thereby making certain legislative or executive...
- Treaty of Paris (1783)Treaty of Paris (1783)The Treaty of Paris, signed on September 3, 1783, ended the American Revolutionary War between Great Britain on the one hand and the United States of America and its allies on the other. The other combatant nations, France, Spain and the Dutch Republic had separate agreements; for details of...
- Jay TreatyJay TreatyJay's Treaty, , also known as Jay's Treaty, The British Treaty, and the Treaty of London of 1794, was a treaty between the United States and Great Britain that is credited with averting war,, resolving issues remaining since the Treaty of Paris of 1783, which ended the American Revolution,, and...