Martin v. Hunter’s Lessee

Impact

Martin v. Hunter's Lessee received mixed reviews from the American public. Northern newspapers generally supported it but gave the case clinical summaries rather than ringing endorsements. On the other hand, southern papers voiced concerns about an increase in federal power over the states. The Richmond Junto's official party organ, the Richmond Enquirer, printed a verbatim copy of Johnson's opinion but not that of Story. Many contemporaries believed that even though Marshall had recused himself from the case, he and Story had informally colluded to craft a nationalistic decision that upheld both the right of the Supreme Court to review state court cases and Marshall's Virginia land claims.

Story's success in defending federal power in Martin inspired the Marshall Court to further expand its authority over state courts in areas like banking, contracts, lottery tickets, and interstate commerce. Yet following the election of Andrew Jackson as president in 1828, the Supreme Court began to moderate its nationalistic approach. The Civil War sparked a revolution in federal-state relations. Union victory solidified federal control over the states and led to the creation of the Fourteenth Amendment, which made the Bill of Rights binding on the states. Following the Great Depression in 1929 and the New Deal of the 1930s, the Supreme Court gradually began to allow the federal government direct control over traditionally state-granted affairs.