Martin v. Hunter’s Lessee
Citation: 14 U.S. (1 Wheat.) 304 (1816)
Facts
A dispute arose over Virginia land grants and their relationship to federal treaties with Britain. The Virginia Court of Appeals refused to comply with a prior Supreme Court mandate (Fairfax’s Devisee v. Hunter’s Lessee), asserting that the Supreme Court had no appellate authority over state courts in matters of federal law.
Issue
Does the Supreme Court have appellate jurisdiction to review state court judgments on questions of federal law?
Holding
Yes. Justice Story held that Section 25 of the Judiciary Act of 1789, which granted the Supreme Court appellate review of state court decisions involving federal questions, was constitutional. The Virginia Court of Appeals was required to comply with the Supreme Court’s mandate.
Rule
The Supreme Court has appellate jurisdiction over state court decisions whenever federal law is at issue. This authority derives from Article III and the Supremacy Clause, and Congress properly conferred it via statute. State court judges are not exempt from Supreme Court review simply because they are independent sovereigns.
Significance
Martin v. Hunter’s Lessee is the foundational case for federal supremacy over state courts on federal questions. It established that the Supreme Court — not each state court acting autonomously — is the final arbiter of federal law, a prerequisite for uniform national law.