Home › Case briefs › Constitutional Law

Martin v. Hunter's Lessee

Supreme Court of the United States · 1816 · Constitutional Law

Constitutional LawJudicial ReviewSupreme Court Appellate JurisdictionFederalismArticle IIISection 25state courtsappellate jurisdiction

Facts

The Court of Appeals of Virginia refused to carry into execution the Supreme Court's prior judgment in this very cause. Virginia's highest court declared that the Supreme Court's appellate power did not extend to it and that the portion of Section 25 of the Judiciary Act authorizing review of its judgments was not in pursuance of the Constitution. The case involved a state-court judgment in which a treaty of the United States and rights claimed under it were drawn in question. The Supreme Court therefore had to decide whether it could review the Virginia court's judgment and whether the case fell within Section 25.

Issue

Whether the Supreme Court's appellate jurisdiction under Article III extends to final judgments of the highest state courts in cases arising under the Constitution, laws, or treaties of the United States, and whether Section 25 of the Judiciary Act validly authorizes such review. Also, whether this case was within the terms of Section 25.

Rule

Article III extends the judicial power of the United States to all cases arising under the Constitution, laws, and treaties of the United States, and Congress may vest that appellate jurisdiction in the Supreme Court over final state-court judgments in such cases. When a final judgment of the highest state court is against a title, right, privilege, or exemption specially set up under a treaty, constitution, or law of the United States, Section 25 permits Supreme Court review.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Oregon, Nadia Flores claims title to a parcel in Portland under a ratified treaty of the United States with a foreign nation. The Oregon Supreme Court enters a final judgment rejecting her treaty-based claim, and Congress has enacted a statute authorizing Supreme Court review of such final state judgments.

May the Supreme Court constitutionally review the Oregon Supreme Court's judgment?

Explanation. Article III extends the federal judicial power to all cases arising under the Constitution, laws, and treaties of the United States, and the Supreme Court has appellate jurisdiction in such cases subject to congressional exceptions and regulations. The majority held that Congress may constitutionally authorize appellate review of final judgments of the highest state courts when a federal treaty right is denied. The source of authority is review of the case, not coercive supervision of state judges as persons.