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Martin v. Hunter’s Lessee
14 U.S. (1 Wheat.) 304, 4 L.Ed. 97 (1816).
Author: Lindsey
Law Involved
Judiciary Act § 25: “That a
final judgment or decree in any suit, in the highest court of law
or equity of a State in which a decision in the suit could be
had, where is drawn in question the validity of a treaty or
statute of, or an authority exercised under, the United States,
and the decision is against their validity; or where is drawn in
question the validity of a statute of, or an authority exercised
under, any State, on the ground of their being repugnant to the
constitution, treaties, or laws of the United States, and the
decision is in favor of such their validity…such clause of
the said Constitution, treaty, statute, or commission, may be
re-examined, and reversed or affirmed in the Supreme Court of the
United States upon a writ of error.”
Facts
A Virginia citizen willed his Virginia land
to his nephew, P, a British subject and resident of
England. Virginia, according to state law, had the right to
confiscate land owned by British subjects and did so.
Virginia granted this land to D, who then ejected P from the
land. But, the treaties of 1783 and 1794 with Great Britain
had anti-confiscation laws saying that the states won’t take
the land of British citizens.
Procedural History
The Virginia district court ruled for P, but
the Virginia Court of Appeals reversed the decision and ruled
against P. The SC reversed the Court of Appeals and
remanded to Virginia Court of Appeals with instructions to enter
judgment for P. The Court of Appeals refused to obey on the
grounds that §25 of the Judiciary Act, which granted the SC
appellate jurisdiction over the Virginia Court of Appeals, was
unconstitutional.
Issues
- Is § 25
of the Judiciary Act unconstitutional in that it extends
the appellate jurisdiction of the Supreme Court to cover
decisions of the state courts?
- If the
Judiciary Act is constitutional, did the Supreme Court
have jurisdiction to hear the case because it covered
“another and ordinary ground of jurisdiction—the
act of compromise”?
Holding
- Yes, §25
is constitutional.
- Yes, the
SC has jurisdiction to hear the case because it concerned
the Act of Compromise (a federal statute).
Reasoning
- Reasons
why it is a good idea for SC to have appellate
jurisdiction over state courts:
§
Article III of the Constitution gives appellate jurisdiction to
the SC in all cases where it doesn’t have original
jurisdiction, subject to the exceptions and regulations imposed
by Congress. (And since in this case the SC doesn’t
have original jurisdiction, it must have appellate jurisdiction)
The framers knew that some federal questions would arise in state
courts and SC would need appellate jurisdiction over state
courts.
§
It has been argued that this appellate jurisdiction over state
courts will impair state’s rights and thus go against the
spirit of the Constitution, but this doesn’t hold water
because Article 1, §10 of the Constitution impairs the state’s
rights on a whole list of items.
§
Another argument against appellate jurisdiction is the abuse of
revising power, but this ultimate power must lie in someone’s
hands and the SC is less likely to abuse it than the state
courts.
§
The Court also reasoned that appellate review of state court
decisions guaranteed uniformity of laws when there exists
conflicts between states.
- The Court
held that it had appellate jurisdiction regarding the
writ of error because the matter concerned a federal
statute and it had appellate jurisdiction over the state
appellate court in the original action because it
concerned a national treaty.
Judgment
The court chooses not to issue a writ of
mandamus to the court of appeals to enforce the former judgments.
Instead, it reverses the case and affirms the judgment of the
district court.
Comments
The Court of Appeals says we are the court
of last resort. If a federal issue comes into our court, we
have the right to have the final say.
The Constitution says nothing about the SC
having power to review state court decisions. But, if there’s
no review, state courts can simply decide not to enforce federal
statutes.
Story says that it doesn’t matter what court
it came from, it matters what the issue at hand is.
If there is a federal question, the SC has a right to be the
final arbiter on the case. In Section 2 clause 2 it says
“In all the other cases before mentioned [ie, in section 2
clause 1- where it mentions US laws and treaties], the Supreme
Court shall have appellate jurisdiction”.
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