Martin v. Hunter's Lessee
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| Martin v. Hunter's Lessee | |
| Reference: 14 U.S. 304 | |
| Term: 1816 | |
| Important Dates | |
| Argued: March 12-14, 1816 Decided: March 20, 1816 | |
| Outcome | |
| Judgment affirmed | |
| Majority | |
| Joseph Story • Bushrod Washington • Henry Brockholst Livingston • Thomas Todd • Gabriel Duvall | |
| Concurring | |
| William Johnson | |
Martin v. Hunter's Lessee is a case decided on March 20, 1816, by the United States Supreme Court holding that the Supreme Court has jurisdiction and authority over state courts regarding federal issues. The case concerned a land dispute in Virginia. The Supreme Court affirmed a prior ruling that had been disputed by the Virginia Court of Appeals.[1][2][3]
Why it matters: The Supreme Court's decision in this case established that federal courts may review state court decisions that rest on federal law or the U.S. Constitution. This provided for the uniform interpretation of federal law throughout the states. To read more about the impact of Martin v. Hunter's Lessee click here.
Background
When Lord Fairfax died in England in 1781, he left his property in the State of Virginia to his nephew, Denny Martin of England. In 1782, the Virginia legislature transferred the land back to Virginia, which then gave part of the property to David Hunter.
The United States had entered into an agreement with Great Britain after the Revolutionary War which would return the land in the United States to British Loyalists who owned the land prior to the war. A Virginia state court ruled in favor of Hunter, despite the state law's conflict with the agreement. The U.S. Supreme Court reversed the ruling on the grounds that the federal treaty superseded the state law.
The State of Virginia was dissatisfied with the decision of the Supreme Court and refused to enforce the ruling. According to the Virginia Court of Appeals, Section 25 of the Judiciary Act of 1789, which allowed the Supreme Court the ability to review the decisions of the lower courts, was unconstitutional. Furthermore, they argued that because states acted as independent governments they had the authority to make the final decisions regarding lawsuits originating in their states. [1][3][4]
Oral argument
Oral argument was held between March 12, 1816, and March 14, 1816. The case was decided on March 20, 1816.[1]
Decision
The Supreme Court decided 6-0 to affirm the Supreme Court's power to override the state court. Justice Joseph Story delivered the opinion of the court. Justice William Johnson wrote a concurring opinion. Chief Justice John Marshall recused himself in the case since he held an interest in the Fairfax land.[2][4]
Opinions
Opinion of the court
Justice Joseph Story, writing for the court, argued that Article III of the U.S. Constitution implicitly states that the Supreme Court has the right to review decisions of a state court. Story elaborated that the U.S. Constitution did not give states total independence from the federal government.
| “ | Such is the language of the article creating and defining the judicial power of the United States. It is the voice of the whole American people solemnly declared, in establishing one great department of that Government which was, in many respects, national, and in all, supreme. It is a part of the very same instrument which was to act not merely upon individuals, but upon States, and to deprive them altogether of the exercise of some powers of sovereignty and to restrain and regulate them in the exercise of others. Let this article be carefully weighed and considered. The language of the article throughout is manifestly designed to be mandatory upon the Legislature. Its obligatory force is so imperative, that Congress could not, without a violation of its duty, have refused to carry it into operation. The judicial power of the United States shall be vested (not may be vested) in one Supreme Court, and in such inferior Courts as Congress may, from time to time, ordain and establish. [5] | ” |
| —Joseph Story, majority opinion in Martin v. Hunter's Lessee[2] | ||
Concurring opinion
Justice William Johnson, in a concurring opinion, wrote that he agreed with the judgment of the court but did not fully support the reasoning stated in Story's opinion.
| “ | God forbid that the judicial power in these States should ever for a moment, even in its humblest departments, feel a doubt of its own independence. Whilst adjudicating on a subject which the laws of the country assign finally to the revising power of another tribunal, it can feel no such doubt. An anxiety to do justice is ever relieved by the knowledge that what we do is not final between the parties. And no sense of dependence can be felt from the knowledge that the parties, not the Court, may be summoned before another tribunal. With this view, by means of laws, avoiding judgments obtained in the State courts in cases over which Congress has constitutionally assumed jurisdiction, and inflicting penalties on parties who shall contumaciously persist in infringing the constitutional rights of others -- under a liberal extension of the writ of injunction and the habeas corpus ad subjiciendum, I flatter myself that the full extent of the constitutional revising power may be secured to the United States, and the benefits of it to the individual, without ever resorting to compulsory or restrictive process upon the State tribunals; a right which, I repeat again, Congress has not asserted, nor has this Court asserted, nor does there appear any necessity for asserting. [5] | ” |
| —William Johnson, concurring opinion in Martin v. Hunter's Lessee[2] | ||
Impact
| Federalism |
|---|
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
Martin v. Hunter's Lessee affirmed the Judiciary Act of 1789, holding that the Supreme Court could review state court decisions regarding federal law. This decision provided for the uniform interpretation of federal law throughout the states.
This case gave the Supreme Court authority to review rulings of state courts, which established the Supreme Court as the most powerful court in the United States. This case also helped to clarify the powers given to the federal court system by the Judiciary Act of 1789.[4]
See also
- The Marshall Court
- Supreme Court of the United States
- History of the Supreme Court
- Article III of the United States Constitution
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 Oyez, "Martin v. Hunter's Lessee," accessed June 21, 2022
- ↑ 2.0 2.1 2.2 2.3 Justia, "Martin v. Hunter's Lessee," accessed June 21, 2022
- ↑ 3.0 3.1 LexisNexis, "Martin v. Hunter's Lessee - 14 U.S. 304, 4 L. Ed. 97, 1816 U.S. LEXIS 333, 1 Wheat. 304," accessed June 21, 2022
- ↑ 4.0 4.1 4.2 PBS, "Landmark Cases: Martin v. Hunter’s Lessee", accessed December 10, 2013
- ↑ 5.0 5.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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