Martin v. Hunter's Lessee

1. Martin v. Hunter's Lessee Branden Kennedy

2. 1816 • A British loyalist during the revolutionary war, Lord Fairfax had his property seized by the state in which he lived, Virginia. Some of the land was assigned to a man named David Hunter. The treaty that ended the war guaranteed the protection of lands owned by loyalists. Upon the death of Fairfax, his nephew, Martin inherited the land, and sued Hunter for the chunk of land back that had been lost during the war. The Virginian court ruled for Martin and Fairfax, but Hunter appealed to the Virginia Court of Appeals, which ruled for Hunter. Martin then appealed to the U.S. Supreme Court, which reversed the decision and held that the tract belonged to Martin and his uncle in accordance to the treaty.

3. 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.

4. 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.

5. Martin vs. Hunter’s Lessee, was a case that help shape the powers of the federal judiciary system, and establish the Supreme Court as the ultimate interpreter of federal law.