Martin v. Hunter’s Lessee
14 U.S. 304 (1816)

  • Hunter claimed some land granted to him by Virginia in 1789, as part of a deal that confiscated lands owned by British subjects.
    • Martin, who owned the land and was a British subject claimed that the confiscation was illegitimate under an anticonfiscation clause of the treaties between the US and UK.
  • The Trial Court found in favor of Martin. Hunter appealed.
  • The Appellate Court reversed. Martin appealed.
    • The Appellate Court found that the State’s title to the land was vested prior to the relevant treaties
  • US Supreme Court reversed the Appellate Court and found for Martin
    • The US Supreme Court found that Virginia had not ‘perfected its title’ before the relevant treaties.
  • The Appellate Court in Virginia refused to reverse their decision!
    • The Appellate Court claimed §25 of the Judiciary Act was unconstitutional insofar as it extended the appellate jurisdiction of the US Supreme Court to the Virginia Court.
      • Basically, the Virginia Court was saying that the US Supreme Court couldn’t overrule their decisions.
    • The Court claimed that §25 placed ‘one sovereign under the direct control of another’, and was therefore unconstitutional.
      • The original idea of the United States was that each individual State was sovereign.
    • The Court claimed that if it is a Federal issue, then it should be filed in a Federal Court.
      • The Court felt that a person can’t start in a State Court and then end up with Federal jurisdiction.
  • The US Supreme Court found that they have appellate jurisdiction over the constitutional decisions made by State Courts?
    • The US Supreme Court found that since the Constitution says that “the Supreme Court shall have appellate jurisdiction,” they can pretty much take any case on appeal that they like, regardless of what the Virginia Appellate Court thinks.
    • The Court found that §10 of Article I of the US Constitution takes a lot of the States sovereignty away anyway, how is this any different?
      • The Constitution, in Article 1 §10 says things like the States can’t enter into treaties, grant titles of Nobility or other things. These are all things that ‘sovereigns’ tend to have, since they don’t have them, they can’t be quite sovereign.
    • The Court found that they must have some input into issues related to the Constitution. Since the Constitution forbids them from acting directly, they therefore must have the duty to act on appeal.
      • It is the “case” and not the “court” that gives the jurisdiction.
      • The State Courts are the initial arbitrators of Federal issues, but they can’t be the final word. States Courts are more likely to be biased than Federal Courts (State judges are elected and subject to political pressure).
      • If a State makes an unconstitutional law, the Supreme Court is the only place where this can be dealt with, since the State Court will likely only enforce State laws.
  • The rule is that in order for the Supreme Court to step in, there must be a:
    • Constitutional Issue
    • Federal Statute Issue, or a
    • International Treaty Issue
  • There are a few very good reasons for why the US Supreme Court should have final appellate jurisdiction for all cases:
    • With respect to the powers granted by the United States, the State judges are not independent, since they have taken an oath to uphold the Constitution.
    • Different State Courts will interpret things differently. A Federal Court is required to help smooth out differences in interpretation. You can’t have asymmetrical interpretation of the law.
    • If Virginia were correct, it would mean that plaintiffs could go ‘forum shopping’ and could find a court that is amenable to their side of the story.