Martin v. Hunter’s Lessee

Citation. 14 U.S. (1 Wheat.) 304 (1816)

Brief Fact Summary.

In a land dispute case, the Supreme Court reversed the decision of the Court of Appeals of Virginia. The Court of Appeals refused to obey the Supreme Court ruling, arguing that the Supreme Court did not have appellate jurisdiction over state courts.

Synopsis of Rule of Law.

The U.S. Supreme Court has appellate jurisdiction over state courts. The federal law establishing this jurisdiction—Section 25 of the Judiciary Act of 1789—was not unconstitutional.

Facts.

A Virginia statute voided grants of land from the English crown. The Governor of Virginia subsequently conveyed land to David Hunter, who leased it to the plaintiff. Before the statute was passed, Lord Fairfax had granted the same land to Denny Fairfax. The U.S. Supreme Court reversed the decision of the Court of Appeals of Virginia in this case, and the Court of Appeals of Virginia refused to obey the U.S. Supreme Court ruling. The Court of Appeals argued that a federal law granting the Supreme Court appellate jurisdiction over state courts was unconstitutional.

Issue.

Does the U.S. Supreme Court have appellate jurisdiction over state courts?

Held.

Yes, the U.S. Supreme Court has appellate jurisdiction over state courts.

Discussion.

According to the Court, Article 3 of the Constitution establishes that U.S. Supreme Court jurisdiction is based on cases, not courts.  Additionally, the Constitution gives the U.S. Supreme Court jurisdiction over all cases arising  under the constitution, laws, and treaties of the United States, and to all cases of admiralty and maritime law. If state courts can hear such cases, but the U.S. Supreme Court did not have appellate jurisdiction over state courts, then the U.S. Supreme Court would only have jurisdiction over some, not all, cases  arising  under the constitution, laws, and treaties of the United States, and some cases of admiralty and maritime law. The Court then establishes that state courts, under Article 6, do in fact hear cases involving the U.S. Constitution, and federal laws.

The Court also holds that U.S. Supreme Court appellate jurisdiction does not impair state judges’ indepencence, because state judges must obey the constitution. The Court also rejects the argument that no public mischief could result from limiting appellate power to state courts, citing issues like state bias in cases in which the state is a party. The Court also cites the interest in uniform caselaw, and equal opportunity for defendants to access Constitutional protections.