Martin v. Hunter'S Lessee


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Martin v. Hunter'S Lessee

The framing of the U.S. Constitution came after the Articles of Confederation failed to create a viable national government. The 13 former colonies had retained most of their political power, and the resulting national government was impotent. In contrast, the U.S. Constitution allocated powers between the national government and state governments. Moreover, the three branches of the national government were given specific grants of power. Despite these provisions and the history of the confederation era, some states were outraged that the U.S. Supreme Court could review and reverse state court decisions. The high court issued such rulings and asserted its jurisdiction without incident until 1813, when the Virginia Court of Appeals refused to enforce the high court's judgment. The case returned to the U.S. Supreme Court in 1816 and led to a landmark decision, Martin v. Hunter's Lessee, 14 U.S. 304 (1816). In a lengthy and magisterial opinion, Justice Joseph Story reaffirmed the Court's jurisdiction and set to rest the idea that state courts could decide whether or not to honor federal court decisions. In addition, the Court raised for the first time that the federal government wielded implied powers as well as enumerated powers.

The legal dispute in question reached back to the Revolutionary War. Following the Declaration of Independence, Virginia passed a law that authorized the confiscation of property held by Loyalists to the British regime. Thomas Lord Fairfax, a Loyalist, held substantial property in Northern Neck, Virginia. After his death, his heir, Denny Martin, sought to claim this property but discovered that it had been confiscated and sold to a private party by the state of Virginia. Martin filed suit in Virginia court, asking the court to eject the current owner and to restore title to him. He based his claim on the Treaty of Paris (1783) and Jay's Treaty (1794), which the U.S. had signed with Great Britain. The Treaty of Paris ended the War for Independence, and Jay's Treaty resolved lingering disputes over parts of the peace treaty. Both treaties contained provisions that forbade the confiscation of Loyalist property. Martin pointed to Article III of the Constitution, which grants the judicial power of the U.S. to the U.S. Supreme Court and gives it jurisdiction to hear disputes involving treaties. He contended that federal treaty provisions trumped state laws. The U.S. Supreme Court agreed in 1813 and ordered Virginia to enforce the Court's judgment restoring title to Martin.

Martin was to be disappointed, as the Virginia Court of Appeals, the commonwealth's highest court, refused to enforce the judgment. It claimed that the U.S. Supreme Court had no power to review state court decisions. Several other states were sympathetic to this viewpoint, signaling a looming crisis over the judicial powers of the national government. It was in this light that the U.S. Supreme Court issued its decision in March 1816. Chief Justice John Marshall, a Virginian with financial and other conflicts of interests, did not participate in the decision, leaving it in the hands of Justice Story and the five other justices.

The Court, in a unanimous decision, rejected Virginia's argument and held that the U.S. Supreme Court had the constitutional and statutory authority to review state court decisions. Justice Story, writing for the Court, conducted a lengthy review of the language of the constitutional and statutory provisions, but he also looked at the historical factors that had led to the framing of Article III. Story, one of the great legal thinkers of the nineteenth century, bluntly dismissed Virginia's claim that the states, in agreeing to the Constitution, had retained their absolute sovereignty. This compact theory of government was, in Story's view, the basis for the Articles of Confederation but not the Constitution. He noted that the Constitution's preamble states that the document was ordained and established "by the people of the United States" and not by the states in their sovereign capacities. The Constitution was not "carved out of existing state sovereignties, nor a surrender of powers already existing in state institutions." In essence, the people had drawn up their government on a clean slate and had allocated powers to the states, the federal government, and to the three branches of the federal government.

This clean slate was evidenced in the allocation of judicial power. Article III laid heavy emphasis on the superiority of the national judicial power in its statement that "the judicial power of the United States shall be vested in such inferior courts as the Congres may from time to time ordain and establish." Story reviewed the text of this provision, using the "natural and obvious sense" of each word. It was illogical to grant the judicial power to a supreme court and then to argue that inferior state courts could take away such power. Therefore, Story concluded that Congress had the duty to vest the "whole judicial power" to the U.S. Supreme Court. The word "shall" loomed large in this discussion, as it signified that Congress did not have discretion to vest less than absolute judicial power. Story also suggested that the federal government held implied powers to execute the commands of the Constitution as well as the enumerated powers contained in the document. Without such implied powers, the government could be hamstrung by pinched readings of its authority to carry out policies for the good of the people.

Having established the constitutional grounds for the right to review state-court decisions, Story turned to Virginia's statutory challenge. Section 25 of the Judiciary Act of 1789, one of the first acts passed by the first Congress, gave the U.S. Supreme Court the authority to issue judgments involving treaty-based lawsuits. Virginia claimed that this violated Article III and the Tenth Amendment, which in essence states that all powers not delegated to the three branches of the federal government are reserved to the states. Justice Story rejected this claim. The U.S. Supreme Court needed to retain jurisdiction over treaties as well as other types of lawsuits named in the Judiciary Act. Story was frank in his criticism. The Constitution had been drafted, in part, to prevent "state attachments, state prejudices, state jealousies, and state interests." Without a manifestly supreme court, states could "obstruct, or control … the regular administration of justice." Moreover, the uniformity of decisions was an important goal. Great mischief would take place if each state could interpret laws, treaties, and the U.S. Constitution. Finally, Story noted that if Virginia's interpretation were to be adopted, the U.S. Supreme Court would have no power to review any state criminal case. Such an interpretation made no sense when the intent of the Framers was reviewed. Therefore, the U.S. Supreme Court had the power to review state-court decisions, and federal judicial supremacy was affirmed.

Further readings

Hall, Kermit L. 1989. The Magic Mirror: Law in American History. New York: Oxford Univ. Press.

Stephens, Otis H., Jr., and John M. Scheb III. 1993. American Constitutional Law. St. Paul, Minn.: West.