Martin v. Hunter’s Lessee – Case Brief Summary
Summary of Martin v. Hunter’s Lessee, 14 U.S. 304, 4 L. Ed. 97, 1 Wheat. 304, 1816 U.S. LEXIS 333 (1816).
The state of Virginia enacted legislation during the Revolutionary War that gave the State the power to confiscate the property of British Loyalists. Hunter was given a grant of land by the State. Denny Martin held the land under devise from Lord Thomas Fairfax.
In an action in ejectment, the trial court found in favor of Martin and the court of appeals (the highest Virginia state court) reversed. The Supreme Court of the United States reversed in favor of Martin, holding that the treaty with England superseded the state statute, and remanded the case to the Virginia court of appeals to enter judgment for Martin. The Virginia court refused, asserting that the appellate power of the U.S. Supreme Court did not extend to judgments from the Virginia court of appeals.
- Does the U.S. Supreme Court have appellate jurisdiction over state court decisions involving federal law?
Holding and Rule
- Yes. The U.S. Supreme Court has appellate jurisdiction over state court decisions involving federal law.
The federal power was given directly by the people and not by the States. Article III, Section 2, Clause 2 of the U.S. Constitution states that “in all other cases before mentioned the Supreme Court shall have appellate jurisdiction”. This demonstrates a textual commitment to allow Supreme Court review of state decisions.
If the Supreme Court could not review decisions from the highest State courts, the state courts necessarily would be excluded from hearing cases involving questions of federal law. It had already been established that state courts have the power to rule on issues of federal law, and therefore the Supreme Court must be able to review those decisions. The Court also held that the Supremacy Clause states that the federal interpretation trumps the states’ interpretation.
The Court rejected concerns regarding state judicial sovereignty. The Supreme Court could already review state executive and legislative decisions and this case was no different. Story then confronted the arguments that state judges were bound to uphold the Constitution just as federal judges were, and so denying state interpretations presumed that the state judges would less than faithfully interpret the Constitution. The Court stated that the issue did not concern bias; rather, it concerned the need for uniformity in federal law. The Supreme Court concluded that the decision by the Virginia court of appeals was in error.
Fifty years after the Supreme Court handed down this opinion, it held in Ex parte McCardle that while the Court’s appellate jurisdiction is subject to exceptions and regulations imposed by Congress, it is derived from the Constitution itself and not from acts of Congress.