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Martin v. Hunter's Lessee (1816)

Martin v. Hunter's Lessee (1816)



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Published by crlstinaaa
Martin v. Hunter's Lessee (1816)

Established the power of judicial review to review decisions of state courts.
Martin v. Hunter's Lessee (1816)

Established the power of judicial review to review decisions of state courts.

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Published by: crlstinaaa on Apr 08, 2009
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Martin v. Hunter's Lessee
[14 U.S. 304] (1816) Facts: Lord Fairfax, a VA citizen, died and left his VA land to his nephew, Martin, a Britishcitizen, resident in England. VA claimed the property was theirs (b/c of state laws confiscatinglands owned by British subjects), and gave it to Hunter. Hunter brought a suit to eject Martinfrom the land, but VA district court found for Martin (b/cVA had not perfected title to land before giving it to Hunter, so status of land is subject to treaties - any land that had not yetescheated to the state it would belong to the British subject). But VA court of appeals reversed,holding that (1) the state's title to the party was perfected before existence of the treaty, andtherefore the treaty didn’t change anything (didn’t give title back to British subject), and(2) theAct of Compromise (1796)(VA state law settled ownership on this land for Hunter)settled thematter against Martin. The SC then reversed that decision, holding that state had not perfectedthe title, and so Martin still had the title, b/c of the treaty against confiscation. The case wasremanded to VA Court of appeals to enter judgment for Martin, but that court refused to obey,declaring that the SC had no right to review the decisions of state courts under the U.S.Constitution.
What's interesting is that SC never mentions the Act of Compromise, which Court of Appeals relies on as well (alternative theories on why land belongs to Hunter). Why wouldthey leave it out?
It's a state law claim, and a state law decision. SC only has jurisdiction when it's afederal question. The state claim (Act of Compromise) can go to fed court under supplemental jurisdiction. But usually, SC will abstain from taking the case altogether when there's a state ground that will also uphold the state court decision. Normally,court would not take the case. But it did, without mentioning the state claim.
Why does VA court think it can ignore the SC ruling?
Judiciary Act extends appellate jurisdiction of SC for fed questions. The VA court of appeals says that the section of the Judiciary Act is unconstitutional. B/c Constitutiondoes not give SC power to review state court decisions. Even if judiciary act wasvalid, should not have gone to SC, b/c Act of Compromise based on state law, so mustuphold state court decision. Issue: Whether the SC has the authority under the Constitution to review,for constitutionality,decision of state courts. - Yes. Reasoning:
Art III states:"The
judicial power shall extend to all cases
, in law and equity, arising under thisConstitution"
The judicial power extends to
federal question cases. So why is it that SC can reviewstate court decisions on constitutionality?
So it has to cover all fed questions whether they arise in state or federal court
So if it's not there on original jurisdiction, then its there under appellate jurisdiction.
The SC must have power to say state court decisions are unconstitutional, and state courtmust listen to them
The jurisdiction is over the case, not the tribunal
So cases may arise in state or fed court. But it may also arise in an int'l court (for atreaty issue), and involves a fed question. Can SC take that case away from the int'ltribunal? NO. So Justice Story is wrong. ALL doesn’t mean all, b/c then it would
include the int'l court. So it SC's power extends from the tribunal. And this goes to theSupremacy Clause. 
Supremacy Clause
declares that the Federal interpretation will trump the States interpretation.
Art VI - "This Constitution, and the laws of the United States . . . and all treaties made, or which shall be made, under the authority of the United States, shall be the supreme law of the land; and the judges in every state shall be bound thereby, anything in the Constitutionor laws of any State to the contrary notwithstanding.
This makes all state Judges bound by federal law. So how do you get from this to SupremeCourt's power of judicial review?
Federal law is supreme over state judges.
Therefore, state courts will deal with federal questions (they have original jurisdiction over these cases)
SC has appellate jurisdiction
. Since state courts may hear fed questions, ThenSupreme Court should have power to also review them.
Art. III, Sec. 2 of Constitution: " In all the other cases before mentioned,the Supreme Court shall have appellate jurisdiction, both as to law andfact, with such exceptions, and under such regulations as the Congressshall make."
If SC couldn’t review decisions from the highest State court, theState courts would be excluded from ever hearing a case in any wayinvolving a Federal question, because the SC couldn’t have appellate jurisdiction in those cases. So, because the States could rule onFederal issues it must be true that the SC can review the decision or the SC would not have appellate jurisdiction in "all other cases."
Therefore, SC can tell Judges whether their decisions are valid
This is a good argument. Patches up the first argument. 
State sovereignty argument rejected
The Spirit of the Constitution argument
It's the spirit of the Constitution to limit the state's powers. State sovereignty iscurtailed by the Constitution.
The Constitution gives many limitations to state governments. The Constitution givesCongress the right to revise, amend or supersede state laws. So states are bound bythe authority of the Federal govt, and so this is consistent with the SC's right toreview state judiciary decisions.
Art I, Sec 10. - List of things states may not do.
This doesn’t impair the independence of state judges, b/c state judges are bound bythe Constitution (federal) 
The absolute right of decision must rest somewhere -so it will be the SC
it is necessary to have a uniform interpretation of the Constitution, Fed Laws, & Treatisesacross the nation in order to avoid differing interpretations among the States.
You have to have uniformity when it comes to Constitutional law - you canthave diff statesinterpreting the Constitution differently. Only way to have uniformity is to have one court.
So why the Supreme Court? - each state will decide in their own interests. So youneed the SC to do this.
Why do we need uniformity? States have diff laws for a lot of things, and this seems to beok.
well, uniformity is not a bad argument, but not perfectly persuasive. 
SC is neutral; State courts are biased.
Conflict between states, so we need a neutral party.
Constitution admits biases and prejudices between states, and they will be jealous of oneanother. 
Historically, SC has told state courts what to do.
And in past, state courts listened, they didn’t argue
Historical precedent was that Supreme Court ruled on these matters, and state courtslistened.
So this gives some legitimacy to the argument now. 
Section 25 of 
Judiciary Act
- authorizes the exercise of jurisdiction in the specified cases
Says Supreme Court has power of judicial review over fed questions decisions of statecourts
The framers of the Constitution also wrote the Judiciary Act, so they intended what theymeant in the Judiciary Act.
Therefore they must have intended that Supreme Court had power to review statecourt decisions
Why was this argument used here, but not in Marbury?
 b/c in Marbury Marshall was arguing that Judiciary Act & Constitution
in conflict.This argument would defeat what Marshall was trying to argue. 
Argument of original understanding
It was publicly avowed by everyone (not just framers) that SC would have power to reviewstate court decisions.
Similar but not the same as history argument 
Class Notes
Is it a good idea for SC to be the final arbiter in what is Constitutional?
Good idea
For efficiency - they will make this decision. If they're wrong we can amend theConstitution.
But ok for SC to rule on other branches (even though counter-Majoritarian dilemma)
There are some things in Constitution that are supposed to
be controlled bythe majority. This is a Madisonian Structure. There are certain rights, protections, roped off from majority control. They are guaranteed to people by

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