Fairfax’s Devisee v. Hunter’s Lessee
Fairfax’s Devisee v. Hunter’s Lessee is a significant Supreme Court case that addresses the complex interplay between state laws and federal authority, particularly concerning property rights and treaty obligations. The case arose from Virginia's decision to uphold the seizure of property owned by Tory Loyalists during the Revolutionary War, prompting questions about the state's compliance with the 1794 Jay Treaty. Justice Joseph Story, writing for a limited majority of justices, ruled in favor of the Loyalists, asserting that Virginia's actions were inconsistent with federal treaty obligations. The ruling highlighted tensions between state sovereignty and federal supremacy, as Virginia responded by declaring the Court's authority to be unconstitutional. This pivotal case ultimately set the stage for further legal disputes, including the follow-up case, Martin v. Hunter's Lessee. The decision underscored the challenges faced by the Supreme Court in asserting its authority over state laws, a theme that resonates in contemporary discussions about the balance of power in the United States.
Fairfax’s Devisee v. Hunter’s Lessee
Date: March 15, 1813
Citation: 11 U.S. 203
Issue: Federal supremacy
Significance: In this case and one in 1816, the U.S. Supreme Court engaged in a constitutional power struggle with the Virginia supreme court over seized Loyalist property and the state’s treaty obligations.
Justice Joseph Story wrote the opinion for himself and only two other justices because three others, Chief Justice John Marshall and Justices Bushrod Washington and Thomas Todd, were not present. Justice William Johnson dissented. The most obvious issue was whether Virginia could pass a law upholding the seizure of property from Tory Loyalists during the Revolutionary War and whether Virginia had to fulfill its obligations under the controversial 1794 Jay Treaty. The Virginia supreme court of appeals upheld the state’s seizure of property from British Loyalists and Virginia’s position on its treaty obligations. Story ruled in favor of the Loyalist claim, but the authority of the Supreme Court was under attack partly because of the narrowness of the Court’s majority. Virginia refused to accept the Court’s authority and declared section 25 of the 1789 Judiciary Act to be unconstitutional. The case returned to the Court as Martin v. Hunter’s Lessee.
