Facts of the case
During the American Revolution, Virginia created laws allowing the state to seize property of Loyalists. In 1781, Denny Martin, a British subject, inherited land from his uncle, 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. A federal treaty dictated that Lord Fairfax was entitled to the property.The Virginia Supreme Court upheld Virginia’s law permitting the confiscation of property, even though it conflicted with the federal treaty. The U.S. Supreme Court reversed and remanded, holding that the treaty superseded state law under the Supremacy Clause of Article VI. On remand, the Virginia Court of Appeals declined to follow the ruling and argued that the law granting the Supreme Court appellate review over state court decisions, section 25 of the Judiciary Act (the Act), was unconstitutional.
Why is the case important?
The state of Virginia granted the same tract of land to the Appellee, Hunter (Appellee), that a federal treaty give to the Appellant, Martin (Appellant). The Supreme Court of the United States (Supreme Court) declared that Appellant was so entitled, but the Virginia Court of Appeals, to which the case was remanded, refused to carryout the Supreme Court’s judgment.
Was section 25 of the Act Constitutional?
Yes. The appellate power of the United States does extend to cases pending in state courts. Section 25 of the Act is supported by the letter and spirit of the Constitution.
The framers obviously contemplated that cases within the Supreme Court’s appellate jurisdiction would arise in state courts. Article VI of the Constitution says that “[the] Constitution and the laws of the United States . . . made in [p]ursuance thereof . . . shall be the supreme law of the land and the judges in every state shall be bound thereby. . . .”
On writ of error, the Supreme Court held that the appellate power of the United States does extend to cases pending in the state courts and that the Judiciary Act § 25, which authorizes the exercise of this jurisdiction in the specified cases, by a writ of error, was supported by the Constitution. The Court reasoned that appellate review of state court decisions guaranteed uniformity of laws, avoided state jealousies and biased interests, and entitled a defendant with the power of removal, which assured defendants equality in asserting their constitutional rights.
- Advocates: –
- Petitioner: Denny Martin
- Respondent: Hunter’s Lessee
- DECIDED BY:Marshall Court
- Location: Supreme Court of Virginia
|Citation:||14 US 304 (1816)|
|Argued:||Mar 12 – 14, 1816|
|Decided:||Mar 20, 1816|