Martin v. Hunter's Lessee 1816
Martin v. Hunter's Lessee 1816
Plaintiff: Thomas Bryan Martin
Defendant: David Hunter
Plaintiff's Claim: That the state of Virginia could not disobey a Supreme Court order to overturn a state law illegally taking land from citizens loyal to the British during the Revolutionary War.
Chief Lawyer for Plaintiff: Jones (first name not recorded)
Chief Lawyer for Defense: Tucker (first name not recorded)
Justices Dissenting: None (John Marshall did not participate)
Date of Decision: March 20, 1816
Significance: The ruling was a historic statement by the Court concerning the supreme judicial review powers of the U.S. Supreme Court over state courts and state law when federal issues are involved. It provided a precedence for numerous other Court decisions involving federal government powers through the following years.
After bitter political struggles with Great Britain over its dominating governmental policies resulting in the war for independence, many Americans opposed creating a strong new federal government. Consequently, the Articles of Confederation, written in 1781, gave the new national government few powers. The document stressed the states' sovereignty (political independence) calling the union between states "a firm league of friendship" and no more. The national government had no powers to tax or regulate commerce (business and trade) and no provisions were made for a federal court system. State courts would hear federal law cases. Each state interpreted federal law their own way leading to inconsistency and confusion with resulting financial and political chaos.
In response to the failures of the Articles of Confederation, a Constitutional Convention was called in 1787 to correct the weaknesses of the Articles. Much debate centered over how to split political power between the national government and the states. Those supporting a more even split in the power between a stronger central, or federal, government and the states were known as Federalists. Those opposed to a stronger national government and supporting continued strong state governments were simply known as anti-federalists. Ultimately, the delegates to the Convention chose a stronger central government.
Though the Constitution as written granted supremacy (higher in power) to the federal government in certain matters and established a Supreme Court, it did not precisely define the balance of power between the states and the federal government. Article VI of the Constitution proclaimed that this "constitution, and the laws of the United States . . . and all treaties made . . . under the authority of the United States, shall be the supreme law of the land." Article III of the Constitution established the Supreme Court. Section 2 of Article III states, "The judicial Power shall extend to all Cases . . . arising under this Constitution, the Laws of the United States, and Treaties made." After much debate in the states over the Constitution creating a stronger central government, it was ratified in 1788. The next year the Judiciary Act of 1789 defined what powers were given to the Supreme Court by the Constitution. The act declared the Court had the power to review state court rulings.
Following ratification of the Constitution, the federalist and anti-federalist debate became so intense that the two groups formed the core of the nation's two primary political parties. The Federalist Party was led by John Adams (1735–1826) and Alexander Hamilton (1755–1804) and the Democratic-Republicans (anti-federalists) by Thomas Jefferson (1743–1826) and James Madison (1751–1836).
Not surprisingly given the raging political debate over federalism, many aspects of the new government were constantly being tested during the first few decades of the nation's history. The early Supreme Court was dominated by judges who were Federalists. When Thomas Jefferson (1801–1809) became president he swore to replace the justices with those who were Democratic-Republicans so as to give greater support to states' rights issues. Although Jefferson failed in his efforts to transform the Court, his successor to the presidency, James Madison (1809–1817) was able to appoint Joseph Story, the Court's first Democratic-Republican justice. Many key early Court decisions addressed the supremacy of the federal powers. Two involved Denny Martin, Fairfax's Devisee v. Hunter's Lessee followed by Martin v. Hunter's Lessee.
Thomas Lord Fairfax's Land
Prior to the Revolutionary War (1775–1783), Thomas Lord Fairfax owned over five million acres of valuable land in the northern part of Virginia. Lord Fairfax, a citizen and resident of Virginia, had originally acquired the land through a charter from the English king. Upon his death in 1781 while the war was still raging, his property was left to his nephew, Denny Martin, a British citizen. Also during the war, the state of Virginia passed a law giving the state authority to confiscate (taking away for the public good) property of Loyalists (those colonists supporting Great Britain), such as Lord Fairfax. Denny Martin died sometime prior to 1803 and the property passed on to his heir, Thomas Bryan Martin. In the meantime, the state confiscated the land and sold it David Hunter. Thomas Martin filed a lawsuit with the state courts of Virginia challenging Hunter's right to the land.
The Virginia court found in favor of Hunter and Martin appealed the decision to the U.S. Supreme Court. The Court in 1813 in Fairfax's Devisee v. Hunter's Lessee decided in favor of Martin. Chief Justice John Marshall did not take part in the case because of a family connection to the Fairfax family. Joseph Story wrote the Court's opinion. Much to the dismay of his fellow Democratic-Republicans, Story held that the Virginia law was unconstitutional. Story found that Martin's ownership of the land was protected by the Treaty of Paris (1783) and Jay's Treaty (1794). Both treaties, signed by the United States and Great Britain following America's victory in the Revolutionary War, provided that property owned by Loyalists would be protected by the U.S. government. In his decision, Story noted that Article VI of the U.S. Constitution stated that treaties are, like laws of Congress, considered the "supreme Law of the Land." Article VI further states that "Judges in every State shall be bound" to the Constitution, federal laws, and treaties regardless of the "Laws of any State." In addition, Section 25 of the 1789 Judiciary Act provided the Supreme Court review power of state court decisions involving issues related to the Constitution, federal laws, and treaties.
Therefore, Story ruled that the treaties negotiated by the federal government took precedence (priority) over conflicting state laws. Martin was the true owner of the property. Story ordered the Virginia court to do the legal work necessary to pass ownership back to Martin. But, the Virginia judges refused. The judges claimed Section 25 violated the powers and rights of state governments.
As a result, Martin filed suit again. The case came back to the Supreme Court to address the constitutionality of the Judiciary Act including the Supreme Court's authority to review state laws and state court decisions. Virginia claimed a state had the right to defy federal treaties or court decisions that the state did not approve of. The Supreme Court, they contended, could only review decisions made by lower federal courts, not state laws or courts.
Story Rules Again
Once again Joseph Story wrote the Court's opinion. Story strongly held that the Supreme Court's appellate jurisdiction (the right to hear appeals of lower court decisions) indeed extended to all cases involving federal issues, both those decided previously in state courts and federal courts. Story wrote that Section 25 of the Judiciary Act was not only constitutional but necessary to guarantee federal laws and treaties were the supreme law of the land.
In rejecting Virginia's claim that states had equal sovereignty to the United States, Story asserted that the American people, not the states, had created the nation. Without the supremacy power of the United States over the states, there could be no nation since no uniform national policies would apply equally throughout the United States. Story wrote,
The constitution of the United States was ordained and established, not by the states in their sovereign capacities, but emphatically, as the preamble
SUPREME COURT JUSTICE JOSEPH STORY
J oseph Story (1779–1845) was born in Marblehead, Massachusetts in September of 1779. After earning a degree at Harvard College and studying law in Boston, he served in the Massachusetts House of Representatives from 1805 to 1808 and in the U.S. House of Representatives from 1808 to 1809. Story became a member of the Democratic-Republican political party which strongly supported states rights in opposition to the Federalists. Because of his political views, he was appointed by President James Madison to the U.S. Supreme Court in 1811 in hopes of influencing the Court's decision in favor of states' rights.
Story served on the Court for thirty-four years during which time he made a lasting mark in U.S. legal history. Though his greatest opinion was in Martin v. Hunter's Lessee (1816), he became Chief Justice John Marshall's closest collaborator on many of Marshall's historic opinions. Much to the dismay of states' rights advocates he strongly supported Marshall's broad interpretations of the Constitution and supremacy of the federal government over state governments.
Story was considered the greatest legal scholar and educator of his time. He was instrumental in restructuring the Harvard Law School where he was a distinguished professor of law. He authored several books which influenced constitutional law throughout the nineteenth century. After Marshall's death in 1835, Story found himself often in the minority on Court decisions with an increased Court emphasis on states' rights. He served on the Court until his death in Cambridge, Massachusetts on September 10, 1845.
[introduction] of the constitution declares, by 'the people of the United States' . . . The constitution was not, therefore, necessarily carved out of powers already existing in state sovereignties, nor a surrender of powers already existing in state institutions . . . [T]he judicial power of the United States [is] . . . national, and . . . supreme . . . to act not merely upon individuals, but upon states; and to deprive them altogether of the exercise of some power of sovereignty, and to restrain and regulate them in the exercise of others.
A Landmark Decision
The opinion by Justice Story is considered the greatest argument ever made for the Supreme Court's judicial review powers over state courts and laws. The decision, which infuriated states' rights proponents, strongly supported the Federalist's position for a strong national government. The decision formed the basis for numerous later court decisions further defining the strong powers of the federal government.
Suggestions for further reading
Dudley, William, ed. The Creation of the Constitution. San Diego, CA: Greenhaven Press, Inc., 1995.
Dunne, Gerald T. Justice Joseph Story and the Rise of the Supreme Court. New York: Simon & Schuster, 1970.
Weissberg, Robert. Understanding American Government. New York: Rinehart and Winston, 1980.