Martin v. Hunter’s Lease

Citation. 1 Wheat. (14 U.S.) 304, 4 L. Ed. 97 (1816)

Brief Fact Summary.

The Virginia Court of Appeals refused to obey the Supreme Court’s order in Fairfax’s Devisee v. Hunter’s Lessee, where the Court ruled that the title of the land shall be vested with Lord Fairfax, not Virginia. Virginia reasoned that the Constitution did not authorize federal courts to act directly upon state court rulings for its opposition to the Supreme Court mandate.

Synopsis of Rule of Law.

The appellate power is not limited by the terms of the Constitution to any particular courts.

Facts.

In 1791, Virginia seized the vast land holdings of Lord Fairfax as lands belonging to British loyalists and parceled out some of the land to its citizens. Hunter, an individual, received a parcel of land from Virginia. Martin received the title of the land from Fairfax and argued  that the title had not vested in Virginia and his title was protected under federal treaty provisions. The Virginia Court of Appeals decided for Hunter but the U.S Supreme Court reversed. However, the Virginia court refused to follow the order holding that “the appellate power of the Supreme Court does not extend to this court.”

Issue.

Does the appellate power of the U.S Supreme Court extend to state courts?

Held.

Yes, the appellate power of the Supreme Court of the United States does extend to state courts and state judges must abide by the decisions of the Supreme Court. Therefore, Virginia must institute the order of the Supreme Court it ruled in Fairfax’s Devisee v. Hunter’s Lessee and shall not seize the Fairfax properties.

Discussion.

The argument that federal courts were never designed to act upon state sovereignty is misguided, because the Constitution is full of provisions which restrain or annual the sovereignty of the states. Such power on federal courts also does not in any way impair the independence of state judges. State judges are not independent but instead are bound to obedience under the Constitution. Judges in each state might interpret the law of the U.S differently and if there were no revising authority to harmonize them into uniformity, the laws would be different from different states.