United States v. Peters

The Court's 1809 decision commanded Judge Peters to act on the mandamus. Chief Justice Marshall pointed out that the disputed certificates had never been the actual property of the state of Pennsylvania. They had always been in the possession of David Rittenhouse or his estate. Since Rittenhouse had always acted as a private citizen in the affair, the Eleventh Amendment prohibition against making a state a party in a lawsuit was not an issue.

In a broader sense, the Court also repudiated the contention that the Pennsylvania legislature's 1801 act demanding the money was legally superior to the federal appeals court decision.

"If the legislatures of the several States may, at will, annul the judgements of the courts of the United States, and destroy the rights acquired under those judgements," wrote Justice Marshall, "the Constitution itself becomes a solemn mockery, and the nation is deprived of the means of enforcing its laws by the instrumentality of its own tribunals."

The Supreme Court declared that states could neither annul the judgements nor determine the jurisdiction of federal courts. Since the court of appeals in the Active case had been formed by the Continental Congress, its decision superceded Pennsylvania's Court of Admiralty. Judge Peters was ordered to act on the mandamus, while making sure that the executrixes of the Rittenhouse estate were protected from any possible legal repercussions. Rittenhouse's papers left no doubt that he had been willing to be rid of the disputed money as soon as its rightful owners were determined.

The Court's decision was extremely unpopular in Pennsylvania. As a matter of national law, however, the decision strengthened the power of federal courts in an era when the struggle over the relative rights of states and the U.S. government was still young.