Martin v. Hunter's Lessee

1 Wheat. (14 U.S.) 304 (1816), argued 12 Mar. 1816, decided 20 Mar. 1816 by vote of 6 to 0; Story for the Court, Marshall not participating. This case involved the constitutionality of section 25 of the 1789 Judiciary Act, which empowered the Supreme Court to review the final judgments of the highest state courts where federal statutes or treaties were involved, or when a state statute or common law rule had been upheld, though challenged under the federal Constitution. Several states, most notably Virginia, condemned section 25 as an unconstitutional authorization for the federal judiciary to usurp state power. States' rights advocates believed that the Union rested on a compact among the states that granted the central government only limited and enumerated powers (see State Sovereignty and States' Rights).

During the War for American Independence, Virginia enacted legislation confiscating Loyalists' property. Thomas Lord Fairfax, a Loyalist, subsequently devised his vast holdings in the Northern Neck to a British subject, but the property had passed into private hands because of the confiscatory statute. The Fairfax interests challenged the Virginia legislation as inconsistent with the state's obligations under the Treaty of Paris (1783) and Jay's Treaty (1794), which protected Loyalist holdings. In Fairfax's Devisee v. Hunter's Lessee (1813), Justice Joseph Story sustained the Fairfax interests. (Chief Justice John Marshall did not participate because of pecuniary interest and prior involvement as counsel.) Story's decision fueled already intense criticism of the Court. States' rights advocates, such as Spencer Roane and Thomas Ritchie, claimed that Story had reduced the states to mere administrative units lacking real sovereignty. The Virginia judiciary refused to enter judgment in favor of Fairfax, effectively denying the validity of section 25 of the 1789 Judiciary Act. The Virginia judges stated that they were under no obligation to obey the Supreme Court.

Virginia's intransigence brought the dispute back to the Supreme Court, this time as Martin v. Hunter's Lessee. Marshall again recused himself, although he played an important behind‐the‐scenes role. The Chief Justice framed the writ of error that brought the case to the Court and consulted extensively with Joseph Story, who again wrote the Court's opinion.

Story's opinion, the most important of his thirty‐four years on the Court, rebuked Virginia for failing to comply with the Court's previous order. Story rejected the compact theory and Virginia's claim that it was equally sovereign with the United States. The American people, Story argued, had created the nation and lodged the national judicial power exclusively in the federal courts. Story sustained section 25 of the 1789 act and insisted that the power to interpret the Constitution had to rest with one ultimate source of authority, which was the United States Supreme Court. He also noted that the national government possessed certain implied powers, a position that Marshall adopted three years later in upholding the Bank of the United States in McCulloch v. Maryland (1819).

Story's opinion was a landmark in the history of federal judicial supremacy. More than even Marshall, Story upheld federal judicial supremacy over the states. Without Story's decision, the Supremacy Clause of the federal Constitution would have lost much of its salience, since the states would not have been bound to conform their laws to a national constitutional standard.

See also Judicial Power and Jurisdiction; Judicial Review.

Bibliography

• G. Edward White, History of the Supreme Court of the United States, vols. 3–4, The Marshall Court and Cultural Change, 1815–35 (1988)

— Kermit L. Hall

• I Wheat. 304 (1816)
• Vote: 6–0
• For the Court: Story
• Not participating: Marshall

Thomas, sixth Lord Fairfax, owned more than 5 million acres of valuable land in the northern area of western Virginia. In 1781 Lord Fairfax died and left his property to a nephew, Denny Martin, a British subject. However, during the War of Independence, Virginia had passed laws confiscating the property of Loyalists, such as Lord Fairfax, who supported Great Britain. The state sold the land to private owners, including David Hunter, who denied Denny Martin's claim to his uncle's property. Martin challenged Hunter's right to this property and filed a lawsuit against him.

The state courts of Virginia decided in favor of Hunter, so Martin took his case to the U.S. Supreme Court. In Fairfax's Devisee v. Hunter's Lessee (1813), the Court decided in favor of Martin. (Chief Justice John Marshall did not participate in this decision because of financial interests in the land at issue.)

Writing for the Court, Justice Joseph Story overturned the Virginia laws used to take the Fairfax lands, reasoning that Martin's inheritance was protected by the Treaty of Paris (1783) and Jay's Treaty (1794). Both of these treaties between the United States and Great Britain pledged that the property of Loyalists in the United States would be protected by the federal government. Justice Story pointed to Article 6 of the Constitution, which included treaties of the United States as part of the “supreme Law of the Land.” Further, Article 6 said that “the Judges in every State shall be bound thereby, any thing in the Constitution or Laws of any State to the Contrary notwithstanding.” Finally, Justice Story referred to Section 25 of the Judiciary Act of 1789, which provided for review by the U.S. Supreme Court of decisions by state courts that involved the U.S. Constitution, federal laws, and treaties.

Justice Story ordered the Virginia Court of Appeals to carry out the decision of the U.S. Supreme Court. The Virginia judges refused to obey the order, however. They claimed that Section 25 of the Judiciary Act of 1789 was not valid because it violated the powers and rights of state governments in the federal Union.

The Issue

Virginia's refusal to comply with Justice Story's ruling brought the case back to the U.S. Supreme Court. The issue cut to the heart of the federal Union. Did the Supreme Court have authority over all state laws and state judicial decisions that involved the U.S. Constitution federal laws, and treaties? Or did each state have authority under the U.S. Constitution to defy certain kinds of federal treaties or decisions if it did not approve of them?

Opinion of the Court

Once again, Joseph Story wrote for the Court. (Chief Justice Marshall again declined to participate because of a possible conflict of interest.) Justice Story decided that the U.S. Supreme Court had jurisdiction in this case, and he rebuked the Virginia judges who had refused to comply with the Court's orders. Contrary to the views of the Virginia judges, Story argued that the U.S. Supreme Court's appellate jurisdiction extended to all cases involving federal issues, not merely to cases coming to it from lower federal courts.

Story asserted that Article 25 of the Judiciary Act of 1789 was constitutional and was necessary to the enforcement of federal laws and treaties as part of the supreme law of the land, as defined by Article 6 of the Constitution. He rejected Virginia's claim to equal sovereignty with the United States and argued that the American people, not the states, had created the federal Union.

Finally, Justice Story insisted that to enforce the supremacy clause of Article 6, the U.S. Supreme Court had the final power to interpret the U.S. Constitution. Without this power over state governments, Story insisted, there could be no enduring federal Union.

Significance

The Court's judgment, expressed by Justice Story, has been called the greatest argument ever made for judicial review of state laws and court decisions by the U.S. Supreme Court. Story's opinion also gave great strength to the nationalists' side of the ongoing argument about state powers and rights in the federal system of the United States. The claims of extreme states' rights advocates, however, were not subdued until after the Civil War.

See also Federalism; Judicial power; Judicial review; Jurisdiction

Justice Joseph Story's opinion in this 1816 case upheld the power of the U.S. Supreme Court to review decisions of all state courts on federal questions as defined in the 1789 Judiciary Act, and upheld the constitutionality of that statute. Story insisted that the framers of the 1787 Constitution had intended the Supreme Court to be supreme in interpretation of the federal Constitution, laws, and treaties to correct "state prejudices" of local judges and assure "uniformity of decisions throughout the whole United States" on such federal questions.

Bibliography

Warren, Charles. The Supreme Court in United States History. Boston: Little, Brown, 1932.

White, G. Edward. The Marshall Court and Cultural Change,1815–1835. New York: Macmillan, 1988.

Martin v. Hunter's Lessee
Supreme Court of the United States
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)
Holding
Article Three of the U.S. Constitution grants the U.S. Supreme Court jurisdiction and authority over state courts on matters involving federal law.
Court membership
Chief Justice John Marshall Associate Justices Bushrod Washington · William Johnson Henry B. Livingston · Thomas Todd Gabriel Duvall · Joseph Story
Case opinions
Majority	Story, joined by Washington, Johnson, Livingston, Todd, Duvall
Concurrence	Johnson
Marshall took no part in the consideration or decision of the case.
Laws applied
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 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 a parcel of land in the area known as the Northern Neck of Virginia. 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 the late Thomas Lord 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 insist that he would assert claim to the title only. 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, 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 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 from the case for financial reasons because he and his brother had signed a contract with Martin to buy the land in dispute. Justice Joseph Story wrote the decision for a unanimous court.

Contents 1 Opinion 2 See also 3 References 4 External links

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 Clause declares that the Federal interpretation will trump the States 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

• Fairfax's Devisee v. Hunter's Lessee, 11 U.S. 603 (1813), predecessor to this case
• Cohens v. Virginia - related case (1821)
• List of United States Supreme Court cases, volume 14
• Jurisdiction stripping

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

• Text of Martin v. Hunter's Lessee, 14 U.S. 304 (1816) is available from:  · Enfacto · Findlaw · LII

• Case Brief for Martin v. Hunter’s Lessee at Lawnix.com

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