Martin v. Hunter’s Lessee
Martin v. Hunter’s Lessee is a significant Supreme Court case that arose in the context of property rights following the American Revolution. The case involved Denny Martin, the heir of loyalist Lord Fairfax, who contested Virginia's law that prohibited foreign subjects from inheriting land. Martin argued that this law violated treaties between the United States and Britain. Initially, the Virginia court, led by Judge Spencer Roane, rejected the Supreme Court's authority to review its decisions, claiming a violation of state sovereignty. However, the Supreme Court, in a unanimous opinion authored by Justice Joseph Story, affirmed its right to review state court rulings, emphasizing the importance of federal judicial authority in interpreting the Constitution and treaties. This ruling not only reinforced federal supremacy but also set a precedent for judicial federalism in the United States. The case underscored the balance of power between state and federal governments and has had lasting implications on the interpretation of law in subsequent cases. Martin v. Hunter’s Lessee is thus a foundational case in the evolution of the American legal system, illustrating the tensions between state rights and national authority.
Martin v. Hunter’s Lessee
Date: March 20, 1816
Citation: 1 Wheat. (14 U.S.) 304
Issue: Judicial federalism
Significance: For the first time, the Supreme Court asserted its appellate jurisdiction to review decisions by state supreme courts.
During the American Revolution, Virginia confiscated the land estate of loyalist Lord Fairfax and sold it to private interests. Virginia also enacted a law denying the right of foreign subjects to inherit land in the state. Fairfax’s English heir, Denny Martin, argued in court that the Virginia law was inconsistent with treaties between the United States and Britain. In Fairfax’s Devisee v. Hunter’s Lessee (1813), the Supreme Court ruled in favor of Martin. The high court of Virginia, headed by Spencer Roane, refused to honor the decision and declared that section 25 of the Judiciary Act of 1789, which authorized the Court’s review of state court decisions, was an unconstitutional violation of Virginia’s sovereignty. The case was returned to the Supreme Court, renamed as Martin v. Hunter’s Lessee.
Speaking for a unanimous Court, Justice Joseph Story repeated the earlier decision, and his forty-page opinion on behalf of federal judicial review is considered a masterpiece. Story insisted that section 25 of the Judiciary Act was “supported by the letter and spirit of the Constitution.” For the purposes of national union and uniformity, it was imperative for the Court to have the final authority to interpret treaties, federal statutes, and the Constitution. Story’s landmark opinion strengthened national sovereignty and the supremacy of the federal judiciary. The major ideas of Martin were reaffirmed in several cases, especially Cohens v. Virginia (1821).