Significance: The Supreme Court ruled that the federal government had supremacy over states and therefore, the federal judiciary had power over state courts.
Background: During the Revolutionary War, the state of Virginia had confiscated lands belonging to Loyalists. Lord Thomas Fairfax, a Loyalist, had owned land in Virginia but fled to England during the war. He died in 1781 and left the land to his nephew, Denny Martin. The following year the Virginia legislature voided the original land grant and gave some of the land to David Hunter. Hunter then rented it to someone else, called the “lessee.” After the war, the federal government had signed two treaties—the Treaty of Paris (1783) and Jay's Treaty (1794)—that required the return of confiscated lands to the rightful owners. These treaties seemed to make clear that Fairfax, and therefore, Martin were entitled to the land. The U.S. Supreme Court declared that the land did belong to Fairfax and his heirs, but the Virginia courts refused to follow the ruling. Virginia argued that the Judiciary Act of 1789, which gave the Supreme Court the right to review state laws that involved the Constitution or treaties, was unconstitutional.
Decision: This case was argued on March 12, 1816, and decided on March 20, 1816, by a vote of 6 to 0. Justice Joseph Story spoke for the Court. Chief Justice John Marshall did not participate because of a conflict of interests. However, he influenced the opinion of the Court. Story's opinion reprimanded Virginia for ignoring the previous ruling. In addition, the Court affirmed that the Supreme Court was the one source with the authority to interpret the Constitution. Thus, states were not equal to the federal government and had to recognize treaties and the rulings of the Supreme Court.
Excerpt from the Opinion of the Court: “The constitution of the United States was ordained and established, not by the states in their sovereign capacities, but . . . by ‘the people of the United States.’ There can be no doubt that it was competent to the people to invest the general government with all the powers which they might deem proper and necessary; to extend or restrain these powers according to their own good pleasure, and to give them a paramount and supreme authority. As little doubt can there be, that the people had a right to prohibit to the states the exercise of any powers which were, in their judgment, incompatible with the objects of the general compact; to make the powers of the state governments, in given cases, subordinate to those of the nation.”
