March 20, 1816 – Supreme Court Decides Martin v. Hunter’s Lessee

Martin v. Hunter’s Lessee (14 US 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 civil matters of federal law.

During the American Revolution, Virginia passed laws allowing the state to seize property of those loyal to Britain. In 1781, Denny Martin, a British subject, inherited land from his uncle, Lord Fairfax, a Loyalist. The following year, the Virginia legislature voided the land grant and transferred the land back to Virginia. Virginia granted a portion of this land to David Hunter. But a federal treaty – the Treaty of Peace of 1783 between the United States of America and Great Britain – dictated that Lord Fairfax, a citizen of Virginia until his death, was entitled to the property. 

Thus, as the online Law Encyclopedia explains:

. . . by virtue of the ‘seal of the commonwealth of Virginia,’ David Hunter owned the land. But by virtue of the Treaty of Paris (1783) and Jay’s Treaty (1794), national treaties that protected Loyalist holdings, the Fairfax heir–Thomas Bryan Martin–owned the land.”

In 1812, Thomas Martin brought suit to establish his claim to the land. The case, known as Fairfax’s Devisee v. Hunter’s Lessee, (11 U.S. 603) was decided by the Supreme Court, which found in favor of Martin and the Fairfax family. Chief Justice Marshall recused himself, since he had purchased much of Martin’s property and so was personally vested in the outcome of the case. The author of the decision was Justice Joseph Story, who found against the state of Virginia. He held that the Treaty of Paris had restored Martin’s title, and that, pursuant to Article VI of the Constitution, treaties were “the supreme law of the land.”

The State of Virginia was infuriated, and the state courts refused to do the legal work necessary to pass the land over to Martin. They said they were under no obligation to obey the Supreme Court.

Once more, Martin brought suit, this time in Martin v. Hunter’s Lessee. Marshall again recused himself, and Story wrote the decision.

The new case framed two of the most important questions for the new constitutional system: Is federal law, including federal treaties, supreme over state law? Is the Supreme Court supreme over the state courts?

Daguerreotype of Supreme Court justice Joseph Story, 1844

The US Supreme Court held that the answers to both of those questions was yes. Justice Story declared in his opinion:

The constitution of the United States was ordained and established, not by the states in their sovereign capacities, but emphatically, as the preamble of the constitution declares, by ‘the people of the United States.’”

He argued that the people had decided to “prohibit to the States the exercise of any powers which were, in their judgment, incompatible with the objects of the general compact, to make the powers of the State governments, in given cases, subordinate to those of the nation . . .”

Furthermore, he pointed out that the sixth article of the Constitution provided that:

This Constitution, and the laws of the United States which shall be made in pursuance thereof, and all treaties made, or which shall be made, under the authority of the United States, shall be the supreme law of the land, and the judges in every State shall be bound thereby, anything in the Constitution or laws of any State to the contrary notwithstanding. [emphasis added]”

Story also made a definitive case for the Supreme Court’s appellate jurisdiction over the state courts pursuant to section 25 of the Judiciary Act of 1789.

Joel Richard Paul, writing in Without Precedent: John Marshall and His Times wrote:

Of more than one thousand opinions issued by the Marshall Court, Martin is among the most significant . . . . While Justice Joseph Story signed the majority opinion, there is strong reason to suspect Marshall had a hand in drafting it. . . . the underlying principles of the decision embody the core of Marshall’s own beliefs about the nature of the Union and the role of treaties in domestic law.” (p. 335)

Today, Paul opines, “Martin remains a cornerstone of the Union.

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