Martin v. Hunter's Lessee

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MARTIN V. HUNTER'S LESSEE

The case of Martin v. Hunter's Lessee (1816) helped shape the jurisprudence of the early Republic by confirming the power of the U.S. Supreme Court to review decisions of state courts. In this case the U.S. Supreme Court reversed a decision by Virginia's highest court. The issues in the case involved the Constitution and the Judiciary Act of 1789, which was one of the first acts passed by Congress. Article VI of the U.S. Constitution provided that the Constitution itself and all laws and treaties made under it "shall be the supreme Law of the Land" and that "the Judges in every State" were obligated to enforce the Constitution, laws, and treaties. Section 25 of the Judiciary Act empowered the U.S. Supreme Court to review cases from the highest courts of the states if those cases involved a federal law or treaty. In Martin v. Hunter's Lessee, the Supreme Court upheld and implemented this provision of the Constitution over the objections of the state of Virginia.

The case involved tens of thousands of acres of land in Virginia that belonged to Thomas, Lord Fairfax, before the Revolution. Fairfax fled to England during the conflict and died there in 1781. His estate went to his nephew, Denny Martin, who was a British citizen. Lord Fairfax required that to claim this land, Martin must change his name to Fairfax, which he readily did. In 1782, with the Revolution still raging, Virginia passed legislation to take the Fairfax lands from the family on the grounds that aliens could not inherit land in the state. David Hunter subsequently bought some of these lands from the state and began a suit to force Fairfax's heirs to vacate the lands. By this time the land had passed to Denny Fairfax's brother, General Philip Martin, who argued that under the Treaty of Paris (1783), which ended the Revolution, and Jay's Treaty (1794), Virginia was obligated to return the lands to their rightful owners. By the time the case reached the Supreme Court, Martin had sold some of his interest in the land to a group of investors that included Chief Justice John Marshall. Thus, the chief justice did not participate in the case.

In Fairfax's Devisee v. Hunter's Lessee (1813), the Supreme Court upheld Martin's claim. However, the Virginia Court of Appeals refused to accept this result and issued an opinion declaring the U.S. Supreme Court had no jurisdiction to review the decision of a state court and that the judges of Virginia were not obligated to obey the Supreme Court. In 1816 the case was back before the Supreme Court as Martin v. Hunter's Lessee. At this point the case was deeply tied to both Virginia politics and the politics of the early nation. Judge Spencer Roane of Virginia, who was the most important figure on his court, despised John Marshall and was a close ally of Thomas Jefferson. His challenge in refusing to accept the Supreme Court's decision was not just legal, but personal and political as well.

With Marshall not participating, Justice Joseph Story of Massachusetts wrote the opinion of the Court. Unlike Marshall, Story was not a Federalist but, rather, had been a Republican congressman appointed to the bench by Jefferson's close friend and ally, James Madison. The Court also included William Johnson, who had been appointed by Jefferson and three other justices appointed by Jefferson or Madison. The political leanings of the justices had no effect on the outcome of the case. All agreed that the Constitution was the "supreme Law of the Land" and that Virginia had to obey the Constitution and the treaties made under it. In a lengthy opinion Story bitterly denounced the states' rights position of the Virginia court. He accused it of resorting to the same antinationalist doctrines that extreme Federalists had invoked just a few years before in resisting the War of 1812. He also exposed the absurdity of the Virginia court's claim that state courts were free to interpret the U.S. Constitution and federal laws as they wished. This would have led to legal anarchy and, as Story put it, "the public mischiefs that would attend such a state of things would be truly deplorable." America's constitutional system required that "the absolute right of decision, in the last resort, must rest somewhere" and that "somewhere" was the U.S. Supreme Court.

Story's opinion in this case is generally considered one of the most important in Supreme Court history. He rejected the states' rights "compact theory" of the Constitution and emphatically endorsed the idea that the U.S. Supreme Court was indeed the final arbiter of the Constitution and the laws and treaties made under it.

See alsoConstitutional Law; States' Rights; Supreme Court .