Martin v. Hunter's Lessee facts for kids

Quick facts for kids 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) 1 Wheat. 304; 4 L. Ed. 97; 1816 U.S. LEXIS 333
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
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 was a very important case decided by the U.S. Supreme Court on March 20, 1816. It was the first time the Supreme Court clearly stated its power to review decisions made by state courts when those decisions involved federal law. This case helped define the balance of power between the federal government and the states.

What Happened?

During the American Revolution, the state of Virginia passed laws to take land from people who supported the British, called Loyalists. Land owned by a Loyalist named Martin was taken by Virginia. This land was then given to David Hunter.

However, the Treaty of Paris (1783), which ended the war, said that such land seizures were not allowed. This meant Martin could sue to get his property back.

The Court Battles Begin

The first court ruled in Martin's favor. But the Virginia state supreme court disagreed. They said the land had been taken correctly. They did not say Virginia law was stronger than U.S. treaties. Instead, they argued the treaty did not apply to this specific land dispute.

The U.S. Supreme Court then reviewed the case, called Fairfax's Devisee v. Hunter's Lessee. They decided the treaty did cover the dispute. So, they sent the case back to the Virginia Supreme Court.

Virginia's Challenge to Federal Power

When the case returned, the Virginia court made a bold statement. They said the U.S. Supreme Court did not have the power to review cases that started in state courts.

They wrote:

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.

This meant the Virginia court refused to follow the U.S. Supreme Court's order.

The Supreme Court's Final Decision

The U.S. Supreme Court then heard the case again on appeal. They overturned Virginia's decision. They ruled that questions about federal law were definitely within their jurisdiction (their power to hear cases). This decision made it clear that the U.S. Supreme Court is the highest authority when it comes to interpreting the U.S. Constitution.

Chief Justice John Marshall usually wrote most of the Supreme Court's opinions back then. But he did not write this one. He stepped aside because he had a conflict of interest. Some of his relatives had an interest in the land involved in the case. Justice Joseph Story wrote the decision for the entire court, which agreed unanimously.

The Court's Judgment

Justice Story first addressed the idea that federal judicial power came from the states. Some argued that the Supreme Court could not overturn a state's decision without the state's permission.

Story explained that the federal government's power came directly from "the people," not from the states. This was clear from history and the beginning of the Constitution.

Why the Supreme Court Can Review State Cases

Story then pointed to Article III, Section 2, Clause 2 of the Constitution. This part shows that the Supreme Court has the power of judicial review over state decisions:

In all Cases affecting Ambassadors, other public Ministers and Consuls, and those in which a State shall be Party, the supreme Court shall have original Jurisdiction. In all the other Cases before mentioned, the supreme Court shall have appellate Jurisdiction, both as to Law and Fact, with such Exceptions, and under such Regulations as the Congress shall make.

Story argued that if the Supreme Court could not review state court decisions, state courts would never have to deal with cases involving federal law. But it was already accepted that states could rule on federal issues. Therefore, the Supreme Court must be able to review these decisions. Otherwise, the Supreme Court would not have "appellate jurisdiction" (the power to review) in "all other cases" as the Constitution states.

Federal Law is Supreme

Also, the Supremacy Clause in the Constitution says that federal interpretations of the law are more important than state interpretations. Story was not worried about states losing their "sovereignty" (their independent power). The Constitution already puts specific limits on state governments. The Supreme Court could already review decisions made by state leaders and lawmakers. This case was no different.

Story also addressed the argument that state judges were just as committed to upholding the Constitution as federal judges. He said the issue was not about whether state judges were biased. The real issue was making sure federal law was interpreted the same way everywhere. He concluded that the state court's decision in this case was wrong.

Justice Story's Words

Justice Story wrote the following in his judgment:

Joseph Story.

The constitution of the United States was ordained and established, not by the states in their sovereign capacities, but emphatically, as the preamble of the constitution declares, by 'the people of the United States.' There can be no doubt that it was competent to the people to invest the general government with all the powers which they might deem proper and necessary; to extend or restrain these powers according to their own good pleasure, and to give them a paramount and supreme authority. As little doubt can there be, that the people had a right to prohibit to the states the exercise of any powers which were, in their judgment, incompatible with the objects of the general compact; to make the powers of the state governments, in given cases, subordinate to those of the nation, or to reserve to themselves those sovereign authorities which they might not choose to delegate to either. The constitution was not, therefore, necessarily carved out of existing state sovereignties, nor a surrender of powers already existing in state institutions, for the powers of the states depend upon their own constitutions; and the people of every state had the right to modify and restrain them, according to their own views of the policy or principle. On the other hand, it is perfectly clear that the sovereign powers vested in the state governments, by their respective constitutions, remained unaltered and unimpaired, except so far as they were granted to the government of the United States.

These deductions do not rest upon general reasoning, plain and obvious as they seem to be. They have been positively recognised by one of the articles in amendment of the constitution, which declares, that 'the powers not delegated to the United States by the constitution, nor prohibited by it to the states, are reserved to the states respectively, or to the people.' The government, then, of the United States, can claim no powers which are not granted to it by the constitution, and the powers actually granted, must be such as are expressly given, or given by necessary implication. On the other hand, this instrument, like every other grant, is to have a reasonable construction, according to the import of its terms; and where a power is expressly given in general terms, it is not to be restrained to particular cases, unless that construction grow out of the context expressly, or by necessary implication. The words are to be taken in their natural and obvious sense, and not in a sense unreasonably restricted or enlarged.

The constitution unavoidably deals in general language. It did not suit the purposes of the people, in framing this great charter of our liberties, to provide for minute specifications of its powers, or to declare the means by which those powers should be carried into execution. It was foreseen that this would be a perilous and difficult, if not an impracticable, task. The instrument was not intended to provide merely for the exigencies of a few years, but was to endure through a long lapse of ages, the events of which were locked up in the inscrutable purposes of Providence. It could not be foreseen what new changes and modifications of power might be indispensable to effectuate the general objects of the charter; and restrictions and specifications, which, at the present, might seem salutary, might, in the end, prove the overthrow of the system itself. Hence its powers are expressed in general terms, leaving to the legislature, from time to time, to adopt its own means to effectuate legitimate objects, and to mould and model the exercise of its powers, as its own wisdom, and the public interests, should require.

The final vote was 6 to 1. Justice Johnson wrote a separate opinion agreeing with the majority.