John Marshall Cases

By: Marco & Chris

Marbury VS Madison (1803)

On his last day in office, President John Adams named forty-two justices of the peace and sixteen new circuit court justices for the District of Columbia under the Organic Act. The Organic Act was an attempt by the Federalists to take control of the federal judiciary before Thomas Jefferson took office. The commissions were signed by President Adams and sealed by acting Secretary of State John Marshall (who later became Chief Justice of the Supreme Court and author of this opinion), but they were not delivered before the expiration of Adams’s term as president. Thomas Jefferson refused to honor the commissions, claiming that they were invalid because they had not been delivered by the end of Adams’s term. William Marbury was an intended recipient of an appointment as justice of the peace. Marbury applied directly to the Supreme Court of the United States for a writ of mandamus to compel Jefferson’s Secretary of State, James Madison, to deliver the commissions. The Judiciary Act of 1789 had granted the Supreme Court original jurisdiction to issue writs of mandamus “…to any courts appointed, or persons holding office, under the authority of the United States.” This is significant because it created the Judicial review and made the system more reliable and they can check each other.

Fletcher VS Peck (1810)

In 1795, nearly every member of the Georgia state legislature was bribed to permit the sale of 30 million acres of land at less than two cents per acre for a total of $500,000. Only one member of the legislature voted against the legislation. The land was known as the Yazoo lands and eventually became the states of Alabama and Mississippi. As a result of public outrage, most of the legislators lost the following election and the new legislature passed a statute in 1796 essentially nullifying the transactions. Those who had purchased the land refused to accept the return of their purchase price and much of the land was resold to bona fide purchasers at great profit. Robert Fletcher purchased 15,000 acres from John Peck in 1803 for $3,000. Peck, in spite of the 1796 statute, had placed a covenant in the deed that stated that the title to the land had not been constitutionally impaired by any subsequent act of the state of Georgia. Fletcher sued Peck to establish the constitutionality of the 1796 act; either the act was constitutional and the contract was void, or the act was unconstitutional and Fletcher had clear title to the land. The constitutional principle is about the Contract Clause that forbids states from passing any "law impairing the obligation of contracts." The significance of this case is the court establishing the Constitution as a bulwark in favor of the rights of property and contract against the mob rule of states. Towards this end, however, other constitutional provisions replace the Contract Clause in importance in later years: in particular, the Fifth and Fourteenth Amendments.

Martin VS Hunter’s Lesse (1816)

The state of Virginia enacted legislation during the Revolutionary War that gave the State the power to confiscate the property of British Loyalists. Hunter was given a grant of land by the State. Denny Martin held the land under devise from Lord Thomas Fairfax. In an action in ejectment, the trial court found in favor of Martin and the court of appeals (the highest Virginia state court) reversed. The Supreme Court of the United States reversed in favor of Martin, holding that the treaty with England superseded the state statute, and remanded the case to the Virginia court of appeals to enter judgment for Martin. The Virginia court refused, asserting that the appellate power of the U.S. Supreme Court did not extend to judgments from the Virginia court of appeals. The constitutional principle is about the court rejecting the claim that Virginia and the national government were equal sovereigns. Reasoning from the Constitution, Justice Story affirmed the Court's power to override state courts to secure a uniform system of law and to fulfill the mandate of the Supremacy Clause. The significance of this case is that overall it weakened the states power and gave more power to the central government.