Summary of Marbury v. Madison (1803)
Relevant Facts: PL Marbury was appointed a justice of the peace at the very end of Adams presidential term, one day before the changing of the guard (3/4/1801), and the appointment was pushed through and confirmed by the Senate. The new administration obtained a repeal of the statute creating the courts and refused to grant Marbury’s commission. Marbury sued incoming Secretary of State James Madison in the Supreme Court for a writ of Mandamus (we command – orders public official to perform a duty under the law).
Marbury contends (1) the Court had the jurisdiction to rule on such a matter; (2) Madison violated federal statutory and constitutional rules by withholding the commission; and (3) the mandamus was an appropriate remedy.
Issue: Under Constitutional law, is the Supreme Court the appropriate court to adjudicate whether a federal commission to serve as a justice of the peace could stand under a new political term?
Under constitutional law, does the new political term’s officers action of denying a previously confirmed appointment under the previous term violate any statutes or rules?
Under constitutional law, is a writ of mandamus an appropriate means to compel the Court to grant a confirmation by a previous President?
Holding: (1) Yes. The Constitution is the law of the land, and all other laws are subservient to it.
(2) Yes. Marbury had vested a legal right in the commission for the term as justice, a right which was not revocable.
(3) Yes, Mandamus was the appropriate legal remedy, for there was no other under the law for Marbury at the time of the suit, other than to go the Federal route in seeing his appointment and subsequent confirmation followed through.
Court’s Rationale/Reasoning: The court may enforce with mandamus because the court has been granted the power under the constitution to use its power when the right claimed is one given by a law of the United States. Otherwise, the Court has mere appellate jurisdiction. However the Constitution does not grant such a power.
So the court must decide here, the means in which to govern: where the constitution may take a back seat to other law, or where the constitution holds overall precedent. Either way, the law or the constitution, must apply totally to the case at hand. In short, it would be betrayal to the very meaning of what the framers of the constitution intended. The constitution must be observed first and foremost; everything else is subservient to it. Both the legislature and executive branches support this ideal.
Rule: The Secretary of State is a person whose actions fall under the scope of the Judicial Act of 1789. Mandamus is the appropriate remedy for the Court to use to enforce its authority on any courts appointed, persons holding office in the United States.
Important Dicta: Aside from the decision, important info…N/A