Plaintiff
Thomas Bryan Martin
Defendant
David Hunter
Plaintiff's Claim
That he, not Hunter, was the rightful owner of a grant of land in Virginia, known as the Northern Neck, left to him by Thomas, Lord Fairfax, a British subject whose title to the land derived from charters from the English kings Charles II and James II.
Chief Lawyer for Plaintiff
Jones
Chief Defense Lawyer
Tucker
Justices for the Court
Gabriel Duvall, William Johnson, Henry Brockholst Livingston, Joseph Story (writing for the Court), Thomas Todd, Bushrod Washington
Justices Dissenting
None (John Marshall did not participate)
Place
Washington, D.C.
Date of Decision
20 March 1816
Decision
That Martin was indeed the rightful owner of the land--and that the Commonwealth of Virginia must recognize the validity of his claim.
Significance
Because the Commonwealth of Virginia had refused to recognize an earlier decision of the Supreme Court awarding the land to Martin, the case was a testingground for whether state or federal power would prevail. Martin v. Hunter's Lessee was one of the major cases establishing the supremacy of federal over state courts.
In the early days of the United States, many aspects of the country's new government were constantly being tested. Because the United States had originated as 13 separate colonies, one of the major conflicts in the new country wasthe tension between state and federal power. Many key court cases in the nation's early decades established the supremacy of the federal government over the states.
The state-federal issue was so central that it helped create the names of thenation's first two political parties. The Federalists, led by John Adams andAlexander Hamilton, believed in a strong central government. Part of their agenda was to insure that a strong elite--almost an aristocracy--would have charge of national affairs, for they tended to mistrust "the common people."
The Democratic-Republicans, on the other hand, led by Thomas Jefferson and James Madison, believed in decentralized power and tended to have faith in theordinary citizen. They saw federal power as less democratic and preferred tosupport the sovereignty of individual states.
The President vs. the Supreme Court
When Jefferson was president, his Democratic-Republican administration had frequently clashed with the Supreme Court, which was dominated by Federalists.Jefferson had even planned to impeach all the justices, in order to replace them with Democratic-Republicans. He actually did impeach Samuel Chase, but when the Senate acquitted Chase, Jefferson's plan was foiled.
Jefferson was succeeded by President James Madison, who was able to appoint the Court's first Democratic-Republican justice, Joseph Story. The Democratic-Republicans hoped that the brilliant Story would be a fitting match for the powerful Federalist chief justice, John Marshall. Instead, Story and Marshallbecame allies.
Rightful Owner or Alien Enemy?
The roots of the Martin case go all the way back to the American Revolution, when Virginia passed laws to confiscate the property of the Loyalists(people still loyal to the King of England). Thomas Lord Fairfax was such a Loyalist, and he chose not to recognize Virginia's action. He simply left theproperty--known as Northern Neck--to Denny Fairfax (previously Denny Martin),a British subject. To confuse matters further, Lord Fairfax, although a Loyalist, was a citizen and resident of Virginia until his death in 1781. His heir, Denny Fairfax, was a native-born British subject who lived in England until his death, sometime between 1796 and 1803.
Meanwhile, the Commonwealth of Virginia had confiscated the Fairfax property,which passed into the hands of David Hunter. Thus, by virtue of the "seal ofthe commonwealth of Virginia," David Hunter owned the land. But by virtue ofthe Treaty of Paris (1783) and Jay's Treaty (1794), national treaties that protected Loyalist holdings, the Fairfax heir--Thomas Bryan Martin--owned theland.
In 1813, Thomas Bryan Martin brought suit to establish his claim to the land.The case, known as Fairfax's Devisee v. Hunter's Lessee, reached theSupreme Court, which found in favor of Martin and the Fairfax family. Marshall, who had a family connection to the Fairfax family, recused himself (took himself off the case). So the author of the decision was the man whom the Democratic-Republicans had trusted to defend states' rights against the federal government, the man they had expected to uphold the rights of the people against the British aristocracy, Justice Story.
Not surprisingly, Story's decision infuriated advocates of states' rights, who claimed that his ruling had reduced the states to mere administrative unitswithout any real power to make important decisions. Virginia, too, was not pleased. The state courts actually refused to do the legal work necessary to pass the land over to Martin. They said they were under no obligation to obeythe Supreme Court.
Once again, Martin brought suit, this time in the case known as Martin v.Hunter's Lessee. Once again, Marshall recused himself while playing an important role behind the scenes. Story again wrote the decision.
"The Supreme Law of the Land"
In a unanimous decision for the Court, Story rebuked the state courts of Virginia for not abiding by the ruling of the Supreme Court. Although state judges are called upon to decide cases, their authority rested not in the laws andconstitution of their own states, Story argued, but rather in the "supreme law of the land"--the U.S. Constitution.
Thus, Story explained, if state courts did not recognize the authority of theappellate court (the court to which cases are appealed), then there is no uniform, national power that applies equally to the entire United States. Eachstate court would then be able to interpret the Constitution as it pleased, which would have the same effect as not having a single constitution to unitethe country.
By the same token, federal laws and treaties must also be open to final interpretation by a single, supreme court. Therefore, Story said, if the Supreme Court interpreted U.S. law and U.S. treaties to mean that Martin and not Hunter was the rightful owner of the Virginia property, the Virginia courts must agree--or face the spectre of a truly divided nation. To quote Story's own words:
Story's opinion in Martin v. Hunter's Lessee is considered the most important in his 34 years on the Court. It stands as a landmark in the historyof "federal judicial supremacy"--the notion that the federal courts are supreme. The story of conflict between states' rights and federal standards has continued throughout the decades, most notably over the issues of slavery and civil rights. Ironically, the perception of which side was "liberal" and which"conservative" has changed over the years, but the issue remains an important one in American politics.
Related Cases
Thomas Bryan Martin
Defendant
David Hunter
Plaintiff's Claim
That he, not Hunter, was the rightful owner of a grant of land in Virginia, known as the Northern Neck, left to him by Thomas, Lord Fairfax, a British subject whose title to the land derived from charters from the English kings Charles II and James II.
Chief Lawyer for Plaintiff
Jones
Chief Defense Lawyer
Tucker
Justices for the Court
Gabriel Duvall, William Johnson, Henry Brockholst Livingston, Joseph Story (writing for the Court), Thomas Todd, Bushrod Washington
Justices Dissenting
None (John Marshall did not participate)
Place
Washington, D.C.
Date of Decision
20 March 1816
Decision
That Martin was indeed the rightful owner of the land--and that the Commonwealth of Virginia must recognize the validity of his claim.
Significance
Because the Commonwealth of Virginia had refused to recognize an earlier decision of the Supreme Court awarding the land to Martin, the case was a testingground for whether state or federal power would prevail. Martin v. Hunter's Lessee was one of the major cases establishing the supremacy of federal over state courts.
In the early days of the United States, many aspects of the country's new government were constantly being tested. Because the United States had originated as 13 separate colonies, one of the major conflicts in the new country wasthe tension between state and federal power. Many key court cases in the nation's early decades established the supremacy of the federal government over the states.
The state-federal issue was so central that it helped create the names of thenation's first two political parties. The Federalists, led by John Adams andAlexander Hamilton, believed in a strong central government. Part of their agenda was to insure that a strong elite--almost an aristocracy--would have charge of national affairs, for they tended to mistrust "the common people."
The Democratic-Republicans, on the other hand, led by Thomas Jefferson and James Madison, believed in decentralized power and tended to have faith in theordinary citizen. They saw federal power as less democratic and preferred tosupport the sovereignty of individual states.
The President vs. the Supreme Court
When Jefferson was president, his Democratic-Republican administration had frequently clashed with the Supreme Court, which was dominated by Federalists.Jefferson had even planned to impeach all the justices, in order to replace them with Democratic-Republicans. He actually did impeach Samuel Chase, but when the Senate acquitted Chase, Jefferson's plan was foiled.
Jefferson was succeeded by President James Madison, who was able to appoint the Court's first Democratic-Republican justice, Joseph Story. The Democratic-Republicans hoped that the brilliant Story would be a fitting match for the powerful Federalist chief justice, John Marshall. Instead, Story and Marshallbecame allies.
Rightful Owner or Alien Enemy?
The roots of the Martin case go all the way back to the American Revolution, when Virginia passed laws to confiscate the property of the Loyalists(people still loyal to the King of England). Thomas Lord Fairfax was such a Loyalist, and he chose not to recognize Virginia's action. He simply left theproperty--known as Northern Neck--to Denny Fairfax (previously Denny Martin),a British subject. To confuse matters further, Lord Fairfax, although a Loyalist, was a citizen and resident of Virginia until his death in 1781. His heir, Denny Fairfax, was a native-born British subject who lived in England until his death, sometime between 1796 and 1803.
Meanwhile, the Commonwealth of Virginia had confiscated the Fairfax property,which passed into the hands of David Hunter. Thus, by virtue of the "seal ofthe commonwealth of Virginia," David Hunter owned the land. But by virtue ofthe Treaty of Paris (1783) and Jay's Treaty (1794), national treaties that protected Loyalist holdings, the Fairfax heir--Thomas Bryan Martin--owned theland.
In 1813, Thomas Bryan Martin brought suit to establish his claim to the land.The case, known as Fairfax's Devisee v. Hunter's Lessee, reached theSupreme Court, which found in favor of Martin and the Fairfax family. Marshall, who had a family connection to the Fairfax family, recused himself (took himself off the case). So the author of the decision was the man whom the Democratic-Republicans had trusted to defend states' rights against the federal government, the man they had expected to uphold the rights of the people against the British aristocracy, Justice Story.
Not surprisingly, Story's decision infuriated advocates of states' rights, who claimed that his ruling had reduced the states to mere administrative unitswithout any real power to make important decisions. Virginia, too, was not pleased. The state courts actually refused to do the legal work necessary to pass the land over to Martin. They said they were under no obligation to obeythe Supreme Court.
Once again, Martin brought suit, this time in the case known as Martin v.Hunter's Lessee. Once again, Marshall recused himself while playing an important role behind the scenes. Story again wrote the decision.
"The Supreme Law of the Land"
In a unanimous decision for the Court, Story rebuked the state courts of Virginia for not abiding by the ruling of the Supreme Court. Although state judges are called upon to decide cases, their authority rested not in the laws andconstitution of their own states, Story argued, but rather in the "supreme law of the land"--the U.S. Constitution.
Thus, Story explained, if state courts did not recognize the authority of theappellate court (the court to which cases are appealed), then there is no uniform, national power that applies equally to the entire United States. Eachstate court would then be able to interpret the Constitution as it pleased, which would have the same effect as not having a single constitution to unitethe country.
By the same token, federal laws and treaties must also be open to final interpretation by a single, supreme court. Therefore, Story said, if the Supreme Court interpreted U.S. law and U.S. treaties to mean that Martin and not Hunter was the rightful owner of the Virginia property, the Virginia courts must agree--or face the spectre of a truly divided nation. To quote Story's own words:
The constitution of the United States was ordained and established, not by the states in their sovereign capacities, but emphatically, as the preamble of the constitution declares, by "the people of the United States" . . . The constitution was not, therefore, necessarily carved out of existing state sovereignties, nor a surrender of powers already existing in state institutions . . . [T]he judicial power of the United States [is established as] . . . one great department which [is] . . . in many respects, national, and in all, supreme. It is a part of the very same instrument which was to actnot merely upon individuals, but upon states; and to deprive them altogetherof the exercise of some powers of sovereignty, and to restrain and regulate them in the exercise of others.
Story's opinion in Martin v. Hunter's Lessee is considered the most important in his 34 years on the Court. It stands as a landmark in the historyof "federal judicial supremacy"--the notion that the federal courts are supreme. The story of conflict between states' rights and federal standards has continued throughout the decades, most notably over the issues of slavery and civil rights. Ironically, the perception of which side was "liberal" and which"conservative" has changed over the years, but the issue remains an important one in American politics.
Related Cases
- Marbury v. Madison, 5 U.S. 137 (1803).
- Fairfax's Devisee v. Hunter's Lessee, 7 Cr. 602 (1813).
- Cohens v. Virginia, 19 U.S. 264 (1821).
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