1. Martin v. Hunter’s Lessee, (1816)
2. Facts: Fairfax, a British loyalist, owned land in Virginia. A Virginia state law provided for the seizure of Fairfax’s lands prior to 1783. Virginia granted the land to Hunter. Martin was the inheritor of the land from Fairfax. Martin claimed that the Peace Treaty of 1783 and the Jay Treaty of 1794 protected the land from seizure.
3. Procedural Posture: The Virginia court, in the original case, found for Hunter The Supreme Court reversed, ordering the Virginia court to enter judgment for Martin under the authority granted by Section 25 of the Judiciary Act which gave the Supreme Court the power to review final decisions of the highest state courts rejecting claims based on federal law. The Virginia state court refused to comply with the order, claiming that Section 25 was unconstitutional, and the Supreme Court had no constitutional right to review the final decisions of the state courts. The case is again being reviewed by the Supreme Court.
4. Issue: Whether Section 25 of the Judiciary Act of 1789 is constitutionally valid, giving the Supreme Court the right to review the final decisions of state courts rejecting claims based on federal law.
5. Holding: Yes.
6. ∏ Argument: Without Supreme Court review of state court decisions, there will be no other mode by which Congress can extend the judicial power of the United States to cases of federal cognizance which arise in the state courts, resulting in non-uniformity of decisions among states.
7. ∆ Argument: The constitution does not provide explicitly for Supreme Court review of state court decisions. Since it must have been foreseen by the drafters that conflicts would arise, the omission is evidence that the framers felt that such a powerful tribunal would produce evils greater than those of the occasional collisions which it would be designed to remedy. Thus, once an action is brought in state court, the federal court’s sole remedy is to shift it to a lower federal court before it gets to the final court of the state, or simply to advise the high state court that they have improperly interpreted the constitution. The states are dually sovereign with the federal government, and not subject to the laws of Congress which limit their sovereignty.
8. Majority Reasoning: In Article III, the Supreme Court is given the judicial power which “shall extend to all cases.” Thus, it is the nature of the case and not the court of origin that determines whether the Supreme Court has appellate jurisdiction. The Supreme Court appellate power is not limited only to cases that come up through the lower federal courts. Also, the Constitution was designed to operate upon the states themselves, and not just the persons within the states. Thus, the states themselves are not equal sovereigns with the federal government, but rather subject to its law-making capability. Furthermore, even if the state courts do not abuse the power of the constitution, they are likely to rule differently on it from state to state. Thus, the need for uniformity in decisions requires an ultimate single court of last resort which exercises review over all states. Lastly, there is substantial historical evidence that the framers intended Supreme Court review of state court decisions, as well as several previous cases which do so.
