Martin v. Hunter's Lessee
|Martin v. Hunter's Lessee|
|Argued March 12, 1816
Decided March 20, 1816
|Full case name||Martin, Heir at law and devisee of Fairfax v. Hunter's Lessee|
|Citations||14 U.S. 304 (more)
4 L. Ed. 97; 1816 U.S. LEXIS 333; 1 Wheat. 304
|Prior history||Judgment for defendant, Hunter v. Fairfax's Devisee, Winchester District Court; reversed, 15 Va. 218 (1810); reversed, sub nom. Fairfax's Devisee v. Hunter's Lessee, 11 U.S. 603 (1813); on remand, sub nom. Hunter v. Martin, 18 Va. 1 (1815)|
|Article Three of the U.S. Constitution grants the U.S. Supreme Court jurisdiction and authority over state courts on matters involving federal law.|
|Majority||Story, joined by Washington, Johnson, Livingston, Todd, Duvall|
|Marshall took no part in the consideration or decision of the case.|
|U.S. Const. art. III|
Martin v. Hunter's Lessee, 14 U.S. 304 (1816), 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 civil matters of federal law.
During the American Revolution, the state of Virginia enacted legislation that allowed it to confiscate Loyalists' 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 plaintiff 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 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, 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, 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.
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 Clause declares that the federal interpretation will trump the state's interpretation.
Story then quickly rejected concerns over State judicial sovereignty. Under Article I, Section 10 the Constitution outlines specific limits 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 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.
- Fairfax's Devisee v. Hunter's Lessee
- Cohens v. Virginia, 19 U.S. 264 (1821) (a parallel case raising the issue of federal judicial review of state criminal, as opposed to civil, matters)
- List of United States Supreme Court cases, volume 14
- Jurisdiction stripping
- Treaty of Paris (1783)
- Jay Treaty
- 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.
- Works related to Martin v. Hunter's Lessee at Wikisource
- Text of Martin v. Hunter's Lessee, 14 U.S. 304 (1816) is available from: Findlaw Justia LII