Green v. Biddle
"Green v. Biddle" is a significant U.S. Supreme Court case from the early 19th century that revolves around land ownership disputes following Kentucky's establishment as a state. The case arose in the context of a 1792 compact between Virginia and Kentucky, which stipulated that land titles in Kentucky would be governed by Virginia law, protecting absentee landowners. However, Kentucky enacted a law allowing settlers to claim compensation for improvements made on land they occupied, regardless of ownership status as defined by Virginia law.
Virginia contested this law, leading to the Supreme Court's intervention. Justice Joseph Story, in his 1821 opinion, ruled that the contracts clause of the U.S. Constitution superseded the Kentucky statute, asserting the primacy of contractual agreements. This decision sparked outrage in Kentucky, prompting a withdrawal and subsequent rehearing of the case. Justice Bushrod Washington ultimately reaffirmed a similar conclusion, yet Kentucky continued to uphold its laws, highlighting the tensions between state legislation and federal authority. The case illustrates early challenges in defining the balance of power between state and federal government, particularly in matters of property rights and contracts.
Green v. Biddle
Date: decided March 5, 1821; redecided February 27, 1823
Citation: 21 U.S. 1
Issue: Contracts clause
Significance: The Supreme Court expanded the contracts clause to include public as well as private contracts.
The 1792 Virginia-Kentucky compact stipulated that Kentucky land titles were to be decided by the preexisting Virginia laws, which protected a number of absentee landowners. However, Kentucky passed a law allowing its settlers to recover the value of improvements they made on land they occupied even if they were not the owners under Virginia law. Virginia objected and took the case to the Supreme Court. In his 1821 opinion for the Court, Justice Joseph Story expanded the contracts clause to include public as well as private agreements and ruled that the contracts clause of the U.S. Constitution prevailed over the Kentucky statute. Kentucky was outraged and forced the Court to withdraw the Story decision. Upon rehearing, Justice Bushrod Washington found essentially the same as Story, but Kentucky continued to enforce its own laws, and the political disagreement over the powers of the Court continued in Congress for some time.
