Martin v. Hunter's Lessee
14 U.S. 304 (1816)

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U.S. Supreme Court

Martin v. Hunter's Lessee, 14 U.S. 1 Wheat. 304 304 (1816)

Martin v. Hunter's Lessee

14 U.S. (1 Wheat.) 304

ERROR TO THE COURT OF APPEALS

OF THE STATE OF VIRGINIA

Page 14 U. S. 305

This was a writ of error to the Court of appeals of the state of Virginia, founded upon the refusal of that Court to obey the mandate of this Court, requiring the judgment rendered in this same cause, at February Term, 1813, to be carried into due execution. The following is the judgment of the Court of appeals, rendered on the mandate:

"The Court is unanimously of opinion that the appellate power of the Supreme Court of the United States does not

Page 14 U. S. 306

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."

Primary Holding
Federal courts have the power to review decisions by state courts that interpret federal law or the Constitution so that the law applies consistently across the states.
Facts
Virginia created laws that allowed it to seize the property of people sympathetic to the British Crown, known as Loyalists, during the American Revolution. In 1791, after the war ended, an ejectment action was brought for the owners of certain land in the Northern Neck region to restore their property rights and remove the current tenants on the land. A British subject, Denny Martin, held the land and asserted a claim to the title. The Court initially ruled in favor of the defendant in the ejectment action.

The plaintiff appealed, and the Virginia Supreme Court upheld Virginia's law permitting the confiscation of property, even though it conflicted with a treaty signed by the federal government after the war. The U.S. Supreme Court reversed and remanded, stating that the treaty trumped state law. The Virginia court maintained its position upon rehearing the case, holding that its interpretation of the treaty controlled and that the Supeme Court did not have the right to impose its interpretation on state courts.

Procedural History

Supreme Court of Virginia - 15 Va. 218 (1810)

Reversed. This was the initial Virginia Supreme Court decision that upehld the confiscation.

U.S. Supreme Court - 11 U.S. 603 (1813)

Reversed and remanded. The Supreme Court found that the treaty did control the dispute, superseding state law.

Supreme Court of Virginia - 18 Va. 1 (1815)

Judgment for the plaintiff. The Supreme Court does not have the power to impose its interpretation of a federal treaty on state courts.

Opinions

Majority

  • Joseph Story (Author)
  • Bushrod Washington
  • William Johnson, Jr.
  • Henry Brockholst Livingston
  • Thomas Todd
  • Gabriel Duvall

Story held that the federal government derived its power directly from the people rather than from the states, and he noted that Article III, Section 2, Clause 2 of the Constitution clearly states that the Supreme Court can review the decision of state courts. Story also relied on the Supremacy Clause in finding that federal interpretations of federal law should supersede state interpretations. Responding to the argument that the Court was infringing on the sovereignty of state courts, Story used the more pragmatic justification of seeking uniform, predictable outcomes across all states. He also noted that the Court's ability to review the decisions of state executive and legislative branches suggested that it could review decisions by the judicial branch as well.

Concurrence

  • William Johnson, Jr. (Author)

Recused

  • John Marshall (Author)

The author of most notable Supreme Court opinions during the early 19th century, Marshall recused himself in this instance because he had arranged to buy the land from Martin and thus had a financial conflict of interest.

Case Commentary

States are considered to have implicitly surrendered some of their powers to the federal government, since the Constitution asserts that the states reserve only the powers that are not delegated to the federal government nor withheld from the federal government by the states.

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