Martin v. Hunter’s Lessee

Martin v. Hunter's Lessee (1816), a landmark U.S. Supreme Court decision in the development of federal-state relations, asserted for the first time the Supreme Court's authority under Section 25 of the federal Judiciary Act of 1789 to hear appellate state supreme court cases involving the constitutionality of federal laws or treaties. Martin v. Hunter's Lessee’s origins lay in 300,000 acres of land in Virginia's “Northern Neck” region, which Charles II of England had granted to the Fairfax family in 1649. In 1776, when the American colonies declared independence from Britain, many colonists—including Thomas Fairfax, the sixth Lord Fairfax—remained loyal to Britain. From 1779 to 1785, however, Virginia's legislature passed several acts confiscating Loyalist-owned lands. When Fairfax died in 1781, he willed his property to his nephew, Denny Martin. The following year, however, Virginia legislators passed an act arguing that Martin, a foreign national, could not inherit property in the Old Dominion. Virginia took formal possession of the Fairfax estate and granted it to private citizens, such as David Hunter, who received 788 acres. To complicate matters, John Marshall, who would become chief justice of the United States, successfully represented Martin's land claims in Hite v. Fairfax (1786). The Fairfax litigation may have led Martin to sell 160,000 acres to a Virginia land speculators cartel that included John and James Marshall.

In 1800 Martin died and willed his land to his brother, Thomas Martin. When Thomas Martin attempted to take the property, Hunter sued him in Virginia court in Hunter v. Fairfax's Devisee (1810). When the Court of Appeals of Virginia upheld Hunter's claim, Martin appealed the decision on a writ of error to the U.S. Supreme Court. As chief justice, Marshall recused himself owing to his financial interests in the Fairfax lands. In Fairfax's Devisee v. Hunter's Lessee (1813), Justice Joseph Story ruled that English common law, international precedents, the Treaty of Paris (1783), and the Jay Treaty (1794) gave Martin title to the land. Story remanded the case to the Virginia courts, ordering them to recognize Martin's claims. In Hunter v. Martin (1815), however, the Court of Appeals of Virginia chief justice Spencer Roane declared that Section 25 of the Judiciary Act of 1789 unconstitutionally violated state sovereignty.

Martin repealed the case to the Supreme Court, and in Martin v. Hunter's Lessee (1816), Story argued that the American people, not the states, created the Constitution, Congress, and federal judiciary and that only impartial federal courts could hear cases involving international law. Under the Judiciary Act of 1789, the Supreme Court had the authority to hear state cases involving international treaties. The Constitution's supremacy clause likewise compelled state judges to abide by federal rulings. Martin, therefore, remained the land's owner. Although it was a defining moment in Story's judicial career, Martin v. Hunter's Lessee was an unpopular decision and a victory for noncitizens' property rights. Land speculators, such as Martin and Marshall, secured fortunes of the expansive estates, while Roane decried the decision as an example of a “consolidationist” Supreme Court increasing the federal government's power at the expense of the states.