Justin Faulkner
PSC 436 - Behrman
Martin v. Hunter’s Lessee
14 U.S. (1 Wheat.) 304 (1816)
Procedural History:
David Hunter filed an action of ejectment against the defendant, Denny Martin, for the
recovery of a parcel of land. Virginia district court ruled in favor of the defendant.
Virginia Court of Appeals reversed the district court’s decision on appeal. Supreme
Court set aside that ruling, but Virginia’s Court of Appeals refused to obey the United
States Supreme Court, claiming Section 25 of the Judiciary Act of 1789 was
unconstitutional and therefore the Supreme Court lacked the authority to reverse a state
court decision (appellate jurisdiction).
Facts:
The state of Virginia, in 1779, acted to confiscate lands owned by British loyalists. One
such parcel of land was a piece of property in the Northern Neck of Virginia, the sole
proprietor of which before the seizure was the late Lord Fairfax. The land was granted
by the state of Virginia to David Hunter, the lessee of whom currently resides there. Lord
Fairfax, however, in his last will and testament, devised the lands to Denny Martin on the
condition that he take on the Fairfax name and arms.
Issue:
1. Who is the rightful owner of the property in question?
2. Is Section 25 of the Judiciary Act of 1789 constitutional?
3. Does the appellate power of United States judiciary extend to cases pending in the
state courts?
Opinion:
1. Martin, heir to Lord Fairfax, is the rightful owner (unanimous).
2. Yes (unanimous)
3. Yes (unanimous)
Reasoning:
Story, C.J.: Article 6, cl. 2 – federal laws/treaties/Constitution are “supreme law of
the land” and state judges are “bound thereby,” state laws/constitutions notwithstanding.
The treaty with Great Britain therefore takes precedence over the authority of Virginia.
Const.: Article 3, sec. 2 grants the federal judiciary appellate jurisdiction over “all cases
arising under the constitution, laws and treaties,” not some cases; cases such as this one
involve just such a federal question.
State judges are bound in obedience to the Constitution. In their original jurisdiction,
they may incidentally consider the laws/treaties/Constitution of the U.S. first. Since the
federal courts have jurisdiction over these cases, if it cannot be original jurisdiction then
it must be of an appellate nature. Federal courts can revise the proceedings of the
executive/legislative branches, so why is this type of review any higher or more
dangerous? Different judges in different states could interpret the Constitution in vastly
different ways; federal appellate jurisdiction provides uniformity. Interstate conflicts can
harm the administration of justice; a coordinating authority is needed to work out these
disputes.