Martin v. Hunter's Lessee (1816)

Martin v. Hunter’s Lessee (1816), is a Supreme Court case that established the Supreme Court’s authority over state courts in matters of federal law.

The plaintiff in this case, Martin, sued the defendant, Hunter’s Lessee, in Virginia State court over a land dispute. The Virginia Court of Appeals decided in favor of Hunter’s Lessee but the Supreme Court of the United States reversed this holding. The Virginia State court rejected the Supreme Court’s reversal stating that Section 25 of the Judiciary Act (a law that granted the United States Supreme Court appellate review power over state-court decisions) was unconstitutional. The State court reasoned that under the principle of dual sovereignty, both State and Federal Supreme Courts were most powerful in their own governments with neither having superiority over the other.

The United States Supreme Court reconsidered the case and upheld the Judiciary Act, reasoning that questions of federal law were within the Supreme Court’s jurisdiction. The Court rejected the notion that state governments held equal sovereignty with the federal government.  The Court emphasized the importance of having a single, coherent interpretation of the Constitution and federal laws rather than multiple competing interpretations from various state courts and referred to Article III which implicitly states that the Supreme Court has the right to review decisions of state courts.

The case established the Supreme Court’s supremacy in matters of constitutional interpretation and over state courts, making it the most powerful court in the United States. In the later half of the nineteenth century, the Court went on to limit its power over state-law issues in appeals that involved federal questions. In Murdock v. Memphis (1874), the Court held that it will only consider cases with federal issues even though a revised Section 25 of the Judiciary Act omitted language indicating that the Court could only decide federal-issues.

[Last updated in July of 2020 by the Wex Definitions Team]