Martin v. Hunter's Lessee

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Martin v. Hunter's Lessee
Court Supreme Court of the United States
Citation
Date decided March 1816

Facts: Martin (D) was heir to the Virginia estates of Lord Fairfax, who died in England in 1781. Through state legislation confiscating the property of British loyalists, Virginia had conveyed title to Hunter. Hunter's lessee (P) brought an action of ejectment. D defended his title by virtue of 2 treaties between the US and Britain that protected such British-owned property. The Virginia Court of Appeals sustained P's claim but was reversed by the US Supreme Court. The Virginia court refused to comply with the reversal, and D again appeals.

Issue: Does the US Supreme Court have appellate jurisdiction over the highest state courts on issues involving the Federal Constitution, laws, and treaties?

Holding: Yes.

Notes:

  • The Judiciary Act of 1789, Section 25, provided for review by the US Supreme Court of final state court decisions rejecting claims under the Federal Constitution and laws. The outcome of this case depends on the Constitutionality of that section
  • Appellate jurisdiction is given by the Constitution to the Supreme Court in all cases where it does not have original jurisdiction, subject to congressional regulations.
  • All cases involving the Constitution, laws, and treaties of the US are included in the judicial power granted by the Constitution to the Supreme Court; hence, all such cases are properly subject to that Court's appellate jurisdiction, and ยง25 of the Judiciary Act.
  • Such power is necessary for a uniformity of decisions throughout the whole US, upon all subjects within the purview of the Constitution

See also[edit | edit source]

  • Marbury v. Madison focuses on federal judicial review while Martin v. Hunter's Lessee focuses on judicial review of state courts.