| Venue: | SCOTUS |
| Facts: | Martin claims he's got title to some land by inheritance from Lord Fairfax, a British citizen. Hunter says VA had taken the land and disposed of it prior to the treaties between the US and England that protected ownership rights of British citizens who owned land in the US. |
| Posture: | Suit in VA court, and Martin wins. VA Ct. App. reverses, saying that Martin lacks a valid claim. SCOTUS holds that Fairfax owned, and validly bequeathed. VA Ct. App. says SCOTUS doesn't have valid power to review state court decisions, and declines to comply. Writ of error. |
| Issue: | Does SCOTUS have the power to review state court judgments? |
| Holding: | Yes. VA Ct. App. is reversed, district court is affirmed. |
| Rule: | The appellate power of the US does extend to cases pending in the state courts, and § 25 of the Judiciary Act authorizing this jurisdiction is constitutional. |
| Reasoning: | It was the people who established the constitution. It wasn't carved
out of existing sovereignties, nor a surrender of powers already
existing in state institutions, because the powers of the states
depend upon their own constitutions, and the people have the
right to modify them. As a result, the government of the US
can claim no powers not granted by the constitution, whether they
are explicitly granted or necessarily implied.
The language of Art III is mandatory upon congress ("shall be vested"). If congress didn't have the obligation to vest that power, there'd be no 3rd branch of government. So obviously, at the very least, a supreme court has to be established. Now congress can't vest judicial power in anything but courts that it creates. And SCOTUS only has appellate jurisdiction over some matters, so there must be inferior courts with original jurisdiction. Because at all times, the whole judicial power must be vested, and the judicial power "shall extend" to the types of cases enumerated. And this jurisdiction is different from state jurisdiction. The state courts couldn't possibly have had jurisdiction over cases arising under the constitution (e.g.) before there was a constitution, and after there was one, there was no way to confer that jurisdiction on them. Art III appellate power isn't limited to any particular courts. It's the case, not the court, that gives jurisdiction. If congress were not to establish certain lower courts, and chose to leave certain matters to the states, the appellate power would still remain. Plus, the supremacy clause: judges in every state are bound by the constitution and US laws. And SCOTUS is the ultimate interpreter of what those are. So obviously the appellate power must extend to state tribunals. Federal courts can review state legislation for constitutionality, after all, so it would be strange if they could not also review judicial holdings. Moreover, we want uniformity of federal law: the constitution needs to mean the same thing in all states. |
| Dicta: | It is a doubtful courst to argue against the use or existence of a
power, form the possibility of its abuse.
We can only construe [the constitution's] powers, and cannot inquire into the policy or the principles which induced the grant of them. Johnson (dissenting): the American people can no longer enjoy the blessings of a free government, whenever the state sovereignties shall be prostrated at the feet of the general government. |