Federal Judicial Review of State Legislation and Judgments Flashcards
Martin v. Hunter’s Lessee
Rule of Law
Under Article III of the United States Constitution, the United States Supreme Court has authority to exercise appellate review of state-court decisions.
Facts
Treaty: Virginia confiscate property of known british loyalists, confiscated from Martin who inherited from Fairfax a loyalist, treaty between US and Britain granted Fairfax land, after confiscated gave to David Hunter. Martin prevailed in state court (abide by treaty and give land back). Court of Appeals reversed upheld land confiscation depsite conflict with federal treaty. US Supreme Court reverse appeals holding Martin as the inheriter was the rightful owner of the property because of the treaty. Instead of following ruling, Virginia court of appeals said SC didn’t have constitutional authority to review state decisions so refused to give land back to martin. AGAIN ended up at SC.
Issue (of round 2)
Does the United States Supreme Court have the authority to exercise appellate review of state-court decisions?
Holding and Reasoning (Story, J.)
Nowhere does it say in article 3 subsection 1+2 that SC cannot have appellate jurisdiction over state matters
It says all cases, treaties included
This problem was over federal treaty and federal treaty trumps state law, reversing, gave land to Martin
Eustis v. Bolles
If the state court would come to the same judgment irrespective of the resolution of the federal issues in the case, the Supreme Court will not review the state court’s holding.
Bolles and Wilde Filed insolvency in county of Suffolk in state of Mass
They Filed same insolvency right after in the same court
Eustis brought an action against them to get his money back in supreme judicial court
Eustis by accepting benefit, sc assumed he waived his right to the composition statutes ***
If decided in state court the same issue, SC won’t review and the lower decision will be sustained
No possibility to change judgement (because not material so anything they say would be an advisory opinion (basically dicta) because he waived, so they don’t have jurisdiction
Supreme court cannot review judgement of state court (have appellate jurisdiction) even if there is a federal question in it if it rests on adequate and independent state grounds *** What is adequate and independent?
Adequate: Must determine if state ground is outcome determinative, if it is, federal issue cannot change judgment
Independent: State law ground also must be independent. State must do own interpretation of state law, which is not compelled by federal law (if the judgment mixes federal and state law and is bouncing back in between the authorities, presumed not independent and SC cam review) (if have headings that separate like 4th amendment and michigan constitution, it clearly shows there is an independent analysis of own state so it is independent)
Example:
Mass Supreme Court
-Search-def wins, not a search state wins
-Two issues: 4th amendment and statute
-4th says it’s not a search, statute says is search (defendant wins and SC CANNOT review)
-4th says no search statute says no search (says same thing so not outcome determinative) (SC can review)
-if taken to SC, can only determine 4th amendment not statute
Addition to Example:
State Mass provision of constitution instead of state constitution
When can USSC have AJ of state court decisions?
The USSC has appellate jurisdiction when a state court’s decision does not clearly rest on state law as an independent ground for the decision (it rested mostly on federal law)
Rule: The U.S. Supreme Court has jurisdiction to review a state court’s decision to provide a defendant with broader procedural protections than those guaranteed in the U.S. Constitution unless the state court explicitly states that its decision is based on separate, adequate, and independent state grounds.
