Martin v. Hunter’s Lessee, 1 Wheaton (14 U.S.) 304; 4 L. Ed. 97 (1816)

Martin v. Hunter’s Lessee, 1 Wheaton (14 U.S.) 304; 4 L. Ed. 97 (1816)

Facts—In the case of Fairfax’s Devisee v. Hunter’s Lessee, 7 Cranch (11 U.S.) 603, the Court reversed the decision of the state court and sustained title to certain Virginia land previously held by Lord Fairfax, a citizen and inhabitant of Virginia until his death in 1781. He devised the land to Denny Fairfax (previously Denny Martin), a native-born British subject who resided in England until his death. The Court held that Denny Fairfax, although an alien enemy, whose property might have been confiscated, was in complete possession of the land at the time of the commencement of the suit in 1791 and up to the treaty of 1794. It was said to be clear “that the treaty of 1794 completely protects and confirms the title of Denny Fairfax, even admitting that the treaty of peace left him wholly unprovided for.” Denny Fairfax died while the suit was still pending, and the Supreme Court vested title in his heirs. Hunter’s lessee claimed title under the Commonwealth of Virginia.

Question—Does the appellate power of the United States extend to cases pending in the state courts?

Decision—Yes.

ReasonJ. Story (6–0). Article III of the Constitution has given appellate jurisdiction to the Supreme Court in all cases under the Constitution where it has no original jurisdiction, subject, however, to such regulations and exceptions as Congress may prescribe. State judges in their official capacities are called on to decide cases, not according to the laws and constitution of their own state, but according to “the supreme law of the land”—the Constitution, laws, and treaties of the United States. Yet to all these cases, the judicial power of this Court is to extend according to the Constitution. It cannot extend by original jurisdiction, so it must extend to them by appellate jurisdiction or not at all.

A final motive, for the appellate power over the state tribunals, is the importance and necessity of uniformity of decisions throughout the United States. Different interpretations would result, and the laws, treaties, and the Constitution of the United States would never have the same construction or efficiency in any two states. For such an evil, the only remedy is the appellate jurisdiction of this Court.

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