Martin v. Hunter's Lessee

14 U.S. 304 (1816)

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Nature of the Case

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Facts

This was a dispute over the ownership of land in Virginia. Hunter (D) claimed that the land was his, granted from Virginia in 1789 as confiscated lands owned by British subjects. Martin (P) claimed that the confiscation was ineffective due to treaties between the United States and England (P was a British subject). The Virginia trial court held for P, but the court of appeals reversed. The United States Supreme Court reversed on the basis of the treaties and matters of federal law, and remanded to the Virginia court of appeals with instructions to enter a judgment for P. The Virginia court of appeals refused to change its decision, claiming section 25 of the Judiciary Act to be unconstitutional because it extended the appellate jurisdiction of Supreme Court to the Virginia court. It claimed that the act put the courts of one sovereign (Virginia) under the direct control of another and that there was nothing in the Constitution to allow for a tribunal by which this dispute could be settled. Therefore, the framers must have thought that such a tribunal would produce evils greater than the occasional collisions that it had been designed to remedy.