Martin: U.S. Supreme Court Jurisdiction Over State Courts

In 1789 the State of Virginia confiscated land owned by British subjects. Hunter claimed some land under a grant from Virginia that same year. Martin, the original owner of the land, asserted that the confiscation was contrary to anti-confiscation clauses in treaties between the U.S. and Britain. Martin v. Hunter's Lessee, 14 U.S. (1 Wheat.) 304 (1816).

The action in Virginia trial court found for Martin, Hunter appealed to the Virginia court of appeals who reversed based on the state's title vesting prior to the treaties. Martin then appealed to the U.S. Supreme Court who reversed and remanded, stating that Virginia did not perfect their title prior to the treaties. On remand, the court instructed the Virginia Court of Appeals to enter judgment for Martin. The Virginia Court declined the instruction stating that section 25 of the Judiciary was unconstitutional in that it extended appellate jurisdiction of the U.S. Supreme Court to the Virginia Court of Appeals. The case found itself before the Supreme Court a second time. Id.

Justice Story, in the opinion for the court, begins by explaining that jurisdiction depends on the case, and not the court. Under the constitution the states are to uphold the constitution, and under the jurisdiction division lined out in the constitution, concurrent jurisdiction in some cases would be inevitable. If the state has original jurisdiction and the issue is a constitutional issue it would naturally follow that the U.S. Supreme Court would be able to exercise appellate jurisdiction in that case on the constitutional issue. Id.

Justice Story further reasons that although ultimate power in the federal courts would be more susceptible to abuse, the constitution presumed "that state attachments, state prejudices, state jealousies, and state interests, might sometimes obstruct, or control, or to be supposed to obstruct or control, the regular administration of justice." Id at 347. Another reason given for the U.S. Supreme Court to have appellate jurisdiction over state courts for constitutional issues is for uniformity in the decisions throughout the U.S. Also Due to the plaintiff having ultimate choice of the court in which to file, allowing the U.S. Supreme Court appellate jurisdiction over state courts would allow the defendant an additional choice of court on appeal. Id.

The court found that the 25th section of the Judiciary Act was constitutional and the Virginia Court of Appeals decision was reversed. Id.

Judicial review of state court cases in Martin was extended to criminal matters in Cohens v. Virginia, 19 U.S. (6 Wheat) 264 (1821).

In Cooper v. Aaron, 358 U.S. 1 (1958), the State of Arkansas had been resisting court ordered desegregation under Brown v. Board of Education, 347 U.S. 483 (1954). The State argued that desegregation would lead to widespread violence and disorder, and that the state of race relations made desegregation dangerous to the communities in Arkansas. The court dismissed that argument by reasoning that "law and order are not here to be preserved by depriving the Negro children of their constitutional rights." Cooper, 358 U.S. at 16. In the Court's opinion Chief Justice Black reasoned that the interpretation of the Fourteenth Amendment stated in Brown is the "supreme law of the land" and therefore binding as from the constitution upon any state in the Union. Cooper, 358 U.S. 1.

This jump from a resource that was considered an authority to assist in decisions to the supreme arbiter of binding authority to the states was an interesting expansion of constitutional power. An expansion of this sort can be frustrating to the modern Federalist movement, however the ruling was necessary to enforce the court's ruling in Brown which was necessary to bring justice to a class of people that had been oppressed for centuries.

The end result of these cases is that the U.S. Supreme Court has binding appellate jurisdiction over state courts where the constitution authorizes appellate jurisdiction over an issue in the case.