Fletcher v. Peck
Fletcher v. Peck is a landmark Supreme Court case from 1810 that emerged from the controversial Yazoo land scandal in Georgia. In 1795, the Georgia legislature granted a vast area of fertile land to speculative companies, a decision marred by allegations of corruption and bribery among legislators. Following a change in the legislature, the state repealed the grant, nullifying all property rights associated with it, which led to disputes among land purchasers, including Robert Fletcher, who sued John Peck to restore his title. The Supreme Court, under Chief Justice John Marshall, ruled that the state’s rescission of the land grant violated the Contract Clause of the U.S. Constitution, establishing that contracts, including legislative grants, must be upheld despite potential corruption in their origin. This decision underscored the Court's role in protecting property rights and set a precedent for future interpretations of contracts and legislative authority. The ruling also highlighted the tension between state actions and federal constitutional principles, marking an important moment in the development of American legal doctrine. The case remains significant in discussions related to property rights, contract law, and the limits of state power.
Fletcher v. Peck
Date: March 16, 1810
Citation: 6 Cranch (10 U.S.) 87
Issues: Contracts clause; property rights
Significance: The Supreme Court’s broad construction of the contracts clause enhanced protection from legislative interference for vested rights in private property. For the first time, moreover, the Court declared that a state law was unconstitutional and therefore invalid.
In 1795 the Georgia legislature granted thirty-five million acres of prime cotton land along the Yazoo River to speculative companies. The price was 1.5 cents per acre. Informed observers believed that members of the legislature had been influenced by bribes and personal interests. The following year, a newly elected legislature rescinded the Yazoo grant and invalidated all property rights deriving from it. Meanwhile, however, third parties in several states had already purchased much of the land. One such person, Robert Fletcher, sued John Peck in federal court, with the goal of having the title restored.
In one of its most unpopular decisions, the Supreme Court found that the rescinding statute had violated the contract clause. Speaking for the Court, Chief Justice John Marshall broadly defined a contract as “a compact between two or more parties,” which included a grant made by a state legislature. Possible corruption in the motives of the legislators was a political question and not germane to the contract’s validity. Marshall wrote that the offending statute was prohibited “either by the general principles which are common to our free institutions, or by the particular provisions of the Constitution.” Justice William Johnson’s concurrence relied solely on the vested law and higher law concept, without reference to the constitutional text.