Cohens v. Virginia
Cohens v. Virginia is a significant Supreme Court case that arose when the Cohen brothers were fined by a Virginia court for selling lottery tickets in violation of state law, despite Congress having authorized such sales for the District of Columbia. The brothers appealed their fine, contending that the Virginia court's actions were unconstitutional. The case addressed the balance of power between state sovereignty and federal authority, particularly in the context of the Eleventh Amendment, which Virginia invoked to claim immunity from Supreme Court review. Chief Justice John Marshall delivered a unanimous opinion, ruling in favor of Virginia but affirming the Court's jurisdiction over state court decisions regarding constitutional issues. He argued that states had relinquished some sovereignty upon joining the national union and that the Eleventh Amendment did not prevent the Court from examining whether state courts had violated federal law. The ruling sparked debate over states' rights, with critics like Thomas Jefferson arguing that it represented a dangerous shift towards increased federal control. This case is a key example of the ongoing tension between state and federal powers in the American legal system.
Cohens v. Virginia
Date: March 3, 1821
Citation: 6 Wheat. (19 U.S.) 264
Issues: Judicial federalism; Eleventh Amendment
Significance: Chief Justice John Marshall used a minor dispute over the sale of lottery tickets in Virginia to assert the Supreme Court’s jurisdiction over state court decisions.
After Congress authorized a lottery sale for the District of Columbia, a Virginia court fined the Cohen brothers one hundred dollars for selling tickets in Virginia in violation of a state statute. The two brothers appealed their fine to the Supreme Court, asserting that the Virginia court had acted unconstitutionally. Virginia claimed immunity from review, based on the Eleventh Amendment as well as principles of state sovereignty. Speaking for a unanimous Court, John Marshall made a narrow ruling in favor of Virginia, with the rationale that Congress had not intended lottery tickets to be sold in states where they were illegal.
Marshall’s opinion in Cohens v. Virginia is memorable because of its vigorous defense of the Court’s broad jurisdiction and the principle of national supremacy. In regard to states’ rights, Marshall argued that the states had surrendered much of their sovereignty when they joined a national union. Taking a narrow reading of the Eleventh Amendment, Marshall wrote that the amendment did not apply when the sole purpose of a suit was to inquire about whether a state court had violated the U.S. Constitution or federal law. Marshall’s lengthy opinion presented a sweeping interpretation of the Court’s appellate jurisdiction over all state court decisions involving issues of national authority. Defenders of states’ rights, including Thomas Jefferson, denounced Cohens as an extreme step toward the consolidation of federal power.