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The 1816 case Martin v. Hunter's Lessee dealt with a Virginia contract dispute but involved the much larger question of whether state courts could interpret the Constitution -- and override the Supreme Court when their opinions differed. Reproduction courtesy of the University of Georgia Archives
In Martin v. Hunter's Lessee (1816), the Supreme Court asserted its authority under Section 25 of the Judiciary Act of 1789 to review state court decisions dealing with federal law. In so doing, the Court rejected the notion of dual judicial sovereignty, in which the state courts and the federal courts have separate and independent domains of power, and instead asserted the primacy of federal courts over federal law.
Martin concerned competing claims to land in Virginia owned by Lord Fairfax, a British loyalist during the Revolutionary War. Virginia seized the land from Fairfax during the war and assigned a tract of it to David Hunter. Following the war, the United States entered into a treaty with Great Britain guaranteeing protection of lands owned by British loyalists like Fairfax. Thomas Martin, Fairfax's nephew inheriting the land upon his death, then sued for recovery of the tract in a Virginia state court. The Virginia court ruled Fairfax and Martin were the proper owners. Hunter appealed to the Virginia Court of Appeals (Virginia's highest court), which ruled that Hunter was the proper owner of the tract. Martin appealed to the U.S. Supreme Court, which reversed the decision and held that the tract belonged to Fairfax and Martin pursuant to the treaty.
The Virginia Court of Appeals refused to obey the Supreme Court's ruling, however, and unanimously held that Hunter was the proper owner of the tract and that the U.S. Supreme Court lacked authority to review and overturn its decisions. The Virginia court maintained that Section 25 of the 1789 Judiciary Act, which expressly allowed the Supreme Court to review decisions of state supreme courts, was unconstitutional. The court argued that the U.S. Constitution did not provide for such a review in its text, and that the states, as independent governments within the federal system, had final say over federal laws in cases litigated in state courts.
On second appeal, the U.S. Supreme Court held that the Constitution did allow the Supreme Court to review state court decisions concerning federal laws (including treaties and the Constitution). Justice Joseph Story wrote the Court's opinion (Chief Justice John Marshall held an interest in Fairfax's land and recused himself from the case). Story first noted that the U.S. Constitution, Article III, implicitly allows Congress to decide whether the Supreme Court may review state decisions of federal law, and that Congress properly authorized such review in passing the Judiciary Act of 1789. Story went on to explain that the Constitution does not guarantee the states total independence from the federal government, and in fact is full of restrictions on state power. While state judges are bound to the same U.S. Constitution and laws as are federal judges, the final interpretation of such laws is best left to a single, competent entity -- the U.S. Supreme Court -- and the Virginia court, therefore, was required to enter judgment in favor of Fairfax. Story's logic is hard to resist, for if the states had the power to interpret the Constitution, there would ultimately be as many versions of the Constitution as there were states.
Martin v. Hunter's Lessee, stands along side of Marbury v. Madison (1803) in shaping the contours of the federal judiciary and establishing the Supreme Court as the ultimate arbiter of federal law. Martin authorized the second great expansion of the federal judiciary in the Marshall Court era and established the primacy of the federal judiciary over state courts on questions of federal law. In just 40 years, the continued weakening of state power would prompt states like Virginia to secede from the Union. Yet the resulting Civil War would permanently vanquish the notion Martin had already weakened -- that the states are independent governments within the federal system able to disobey and even withdraw their ties with Washington on a whim.
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AUTHOR'S BIO
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Alex McBride is a third year law student at Tulane Law School in New
Orleans. He is articles editor on the TULANE LAW REVIEW and the 2005
recipient of the Ray Forrester Award in Constitutional Law. In 2007, Alex
will be clerking with Judge Susan Braden on the United States Court of
Federal Claims in Washington.
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