Martin v. Hunter's Lessee

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Martin v. Hunter's Lessee
Supreme Court of the United States
Argued March 12, 1816
Decided March 20, 1816
Full case name: Martin, Heir at law and devisee of Fairfax v. Hunter's Lessee
Citations: 14 U.S. 304; 4 L. Ed. 97; 1816 U.S. LEXIS 333; 1 Wheat. 304
Prior history: Judgment for defendant, Hunter v. Fairfax's Devisee, Winchester District Court; reversed, 15 Va. 218 (1810); reversed, sub nom. Fairfax's Devisee v. Hunter's Lessee, 11 U.S. 603 (1813); on remand, sub nom. Hunter v. Martin, 18 Va. 1 (1815)
Holding
Article Three of the U.S. Constitution grants the U.S. Supreme Court jurisdiction and authority over state courts on matters involving federal law.
Court membership
Chief Justice: John Marshall
Associate Justices: Bushrod Washington, William Johnson, Henry Brockholst Livingston, Thomas Todd, Gabriel Duvall, Joseph Story
Case opinions
Majority by: Story
Joined by: Washington, Johnson, Livingston, Todd, Duvall
Concurrence by: Johnson
Marshall took no part in the consideration or decision of the case.
Laws applied
U.S. Const. art. III

Martin v. Hunter's Lessee, 14 U.S. 304 (1816), was a landmark United States Supreme Court case decided on March 20, 1816. It was the first case to assert ultimate Supreme Court authority over state courts in matters of federal law.

During the American Revolution, the state of Virginia enacted legislation that allowed it to confiscate Loyalistsproperty. One such Loyalist named Denny Martin sued on the grounds that treaties with Great Britain guaranteed protection of Loyalist property. The Virginia state supreme court upheld the confiscation. It did not do so on the grounds that Virginia law was superior to U.S. treaties, but rather because it argued that its own interpretation of the treaty revealed that the treaty did not, in fact, cover the dispute. On review, the U.S. Supreme Court disagreed with this conclusion, ruling that the treaty did in fact cover the dispute, and remanded the case back to the Virginia Supreme Court, but the Virginia court then argued that the U.S. Supreme Court did not have authority over cases originating in state court. The U.S. Supreme Court reversed the state court’s decision on appeal, ruling that questions of federal law were within its jurisdiction, and thereby establishing its own supremacy in matters of constitutional interpretation.

Though Chief Justice John Marshall wrote most of the Supreme Court opinions during his tenure, he did not write this opinion. Marshall instead recused himself from the case for financial reasons because he and his brother had signed a contract with Martin to buy the land in dispute. Justice Joseph Story wrote the decision for a unanimous court.

  • Jean Edward Smith, John Marshall: Definer Of A Nation, New York: Henry Holt & Company, 1996.
  • Jean Edward Smith, The Constitution And American Foreign Policy, St. Paul, MN: West Publishing Company, 1989.

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