Martin v. Hunter's Lessee
| Martin v. Hunter's Lessee | |
|---|---|
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| Argued March 12, 1816 Decided March 20, 1816 |
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| Full case name | Martin, Heir at law and devisee of Fairfax v. Hunter's Lessee |
| Citations | 14 U.S. 304 (more)
4 L. Ed. 97; 1816 U.S. LEXIS 333; 1 Wheat. 304
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| Prior history | Judgment for defendant, Hunter v. Fairfax's Devisee, Winchester District Court; reversed, 15 Va. 218 (1810); reversed, sub nom. Fairfax's Devisee v. Hunter's Lessee, 11 U.S. 603 (1813); on remand, sub nom. Hunter v. Martin, 18 Va. 1 (1815) |
| Holding | |
| Article Three of the U.S. Constitution grants the U.S. Supreme Court jurisdiction and authority over state courts on matters involving federal law. | |
| Court membership | |
| Case opinions | |
| Majority | Story, joined by Washington, Johnson, Livingston, Todd, Duvall |
| Concurrence | Johnson |
| Marshall took no part in the consideration or decision of the case. | |
| Laws applied | |
| U.S. Const. art. III | |
Martin v. Hunter's Lessee, 14 U.S. 304 (1816) was a landmark United States Supreme Court case decided on March 20, 1816. It was the first case to assert ultimate Supreme Court authority over state courts in civil matters of federal law.
During the American Revolution, the Commonwealth of Virginia enacted legislation that allowed it to confiscate Loyalists' property. Here, the original suit was an action of ejectment brought in Virginia state court for the recovery of land in the state known as the Northern Neck Proprietary. A declaration in ejectment was served in April 1791 on the tenants in possession of the land. Denny Fairfax (late Denny Martin) was a British subject who held the land under the devise of Lord Thomas Fairfax. Denny Martin was admitted to defend the suit and plead the general issue upon the usual terms of confessing lease, entry, and ouster. Martin agreed to assert only claim to the title. The facts being settled in the form of a case agreed to be taken and considered as a special verdict, the court, on consideration thereof, gave judgment in favor of the defendant in ejectment on April 24, 1794. From that judgment the plaintiff in ejectment (now plaintiff in error) appealed to the court of appeals.
The Virginia state supreme court upheld the confiscation. It did not do so on the grounds that Virginia law was superior to U.S. treaties, but rather because it argued that its own interpretation of the treaty revealed that the treaty did not, in fact, cover the dispute. On review in Fairfax's Devisee v. Hunter's Lessee, 11 U.S. 603 (1813), the U.S. Supreme Court disagreed with this conclusion, ruling that the treaty did in fact cover the dispute, and remanded the case back to the Virginia Supreme Court, but the Virginia court then decided that the U.S. Supreme Court did not have authority over cases originating in state court:
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