Martin v. Hunter’s Lessee


Virginia established a law during the Revolutionary War giving the state the authority to confiscate the property of British Loyalists. Defendant was given a grant of land by the State after the land was seized by the State of Virginia.  Plaintiff originally held the land granted to him from a British Lord who was his uncle.  However, the Jay Treaty at the end of the American Revolutionary War granted title to Plaintiff, according to Plaintiff.

The trial court found in favor of Plaintiff, but was later reversed on appeal. The Supreme Court then reversed in favor of Plaintiff Martin, holding that the treaty with England was federal law that predominated state law.  The Supreme Court then remanded the case to the lower court of appeals to enter its judgment in favor of Plaintiff. The Virginia Court of Appeals refused, on the basis that the appellate power of the U.S. Supreme Court did not extend to judgments from the Virginia court of appeals where a federal law is at issue.  More specifically, the Virginia Court of Appeals held that Section 25 of the Judiciary Act was unconstitutional, thereby rendering the Supreme Court’s order unenforceable.


Whether the Supreme Court has appellate jurisdiction (can hear and make ruling on appeals) over state court decisions regarding federal laws.


Yes, judgment reversed.  Article III, Section 2, Clause 2 holds:  “in all other cases before mentioned the Supreme Court shall have appellate jurisdiction”.  The court established and relied on the Supremacy Clause, which states that Supreme Court interpretation of federal law trumps state court interpretation of federal law.  Much in the same way that state courts can review federal laws and rightfully decide on their merits, so too should federal courts and the U.S. Supreme Court be able to rule on federal law.

Moreover, it had already been decided that SCOTUS could review state legislative and executive decisions.  The review of these decisions directly pertained to state law; therefore, extending appellate jurisdiction over state court decisions is really no extension at all – it is already being done.  Moreover, it is necessary for SCOTUS to have appellate jurisdiction over federal law because federal law ought to have a uniform interpretation.  It is poor policy for federal law to be interpreted by one state and simultaneously interpreted differently in another state.  Uniform interpretation ensures uniform application of the law as the law was written by Congress.  Having no review over federal law would be like having no federal at all, as any state court could interpret the law to fit its own desired outcome.

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