Judicial Review Cases / Justiciabilty Unit 2

Question 1

Case: Marbury V Madison

Answer 1

Facts
Despite their commissions being signed and sealed, they were not delivered by the time President Thomas Jefferson took office. Jefferson, opposing the appointments, instructed his Secretary of State, James Madison, not to deliver the commissions. Marbury then petitioned the Supreme Court for a writ of mandamus to compel Madison to deliver the commissions.

Issue
The central legal issue was whether Marbury had a right to the commission he was denied and, if so, whether the law provided him a remedy. Furthermore, the case questioned whether the Supreme Court had the authority to issue a writ of mandamus in this situation.

Reasoning
e Court reasoned that Marbury’s commission was valid upon signing by the President and sealing by the Secretary of State, creating a vested right to the office. However, the portion of the Judiciary Act of 1789 that enabled Marbury to bring his claim directly to the Supreme Court was found to be unconstitutional, as it extended the Court’s original jurisdiction beyond what was stipulated in Article III of the Constitution. The Court concluded that when an act of Congress is in conflict with the Constitution, the Constitution must prevail, and the courts have the duty to uphold the Constitution by voiding the conflicting law. This case marked the first time the Supreme Court struck down a law by declaring it unconstitutional, establishing the doctrine of judicial review.

Holding
The Supreme Court held that Marbury had a right to his commission but the Court did not have the authority to issue a writ of mandamus to enforce it. This decision established the principle of judicial review, affirming the Court’s power to declare acts of Congress unconstitutional.

Question 2

Case : Martin v. Hunter’s Lessee, 14 U.S. (1 Wheat.) 304 (1816),

Answer 2

Martin v. Hunter’s Lessee, 14 U.S. (1 Wheat.) 304 (1816), is a foundational Supreme Court case that affirmed the Court’s authority to review decisions made by state courts involving federal law. Below is a summary:

The case arose from a land dispute in Virginia. During the Revolutionary War, Virginia confiscated land owned by British loyalists and granted it to private parties. One such case involved land granted to Hunter by Virginia, but

Martin claimed the same land under a treaty between the U.S. and Great Britain, which protected British property rights.

Martin argued that the treaty superseded Virginia’s law under the Supremacy Clause of the U.S. Constitution.

The Virginia Court of Appeals ruled in favor of Hunter, disregarding the federal treaty.

Procedural History:

The U.S. Supreme Court reversed the Virginia decision, holding that the treaty was controlling.
Virginia refused to comply with the Supreme Court’s ruling, challenging its authority to review state court decisions.

Issue:

Does the U.S. Supreme Court have the authority to review decisions made by state courts that involve federal law?
Holding:

Yes, the U.S. Supreme Court has the authority to review state court decisions involving federal law.

easoning (Justice Joseph Story):

The Constitution’s Article III, Section 2, extends the judicial power to cases arising under federal laws and treaties.
The appellate jurisdiction of the Supreme Court includes cases arising from state courts when federal law is at issue.
Without this authority, federal laws and treaties would lack uniform interpretation and enforcement across states, undermining the supremacy of federal law.
The Constitution creates a unified judicial system to ensure the supremacy of federal law.
mpact:

Martin v. Hunter’s Lessee established the principle that the Supreme Court has appellate jurisdiction over state court decisions in cases involving federal law. It reinforced the supremacy of the federal judiciary in interpreting federal law and the Constitution.

Question 3

Ase: Maryland v. Baltimore Radio Show, Inc., 338 U.S. 912 (1950),

Answer 3

Case Overview
Facts:

This case involved the Maryland State Tax Commission and the Baltimore Radio Show, Inc. in a tax dispute.
The specific facts of the underlying tax issue are less significant than the procedural question it raised concerning the Supreme Court’s certiorari process.
Key Procedural Issue:

The Supreme Court declined to hear the case by denying a writ of certiorari (a discretionary appeal process).
Justice Frankfurter authored a memorandum explaining that a denial of certiorari should not be interpreted as the Court’s approval or disapproval of the lower court’s decision. This clarification emphasized that certiorari denials are not decisions on the merits of a case.
Importance:

Maryland v. Baltimore Radio Show is cited for establishing that the Supreme Court’s denial of certiorari does not reflect the Court’s opinion on the merits of the case.
It illustrates that the denial could result from various reasons, including caseload considerations, procedural issues, or the case’s lack of national significance.
Implications:

This principle has been significant in ensuring that lower courts and legal scholars do not overinterpret certiorari denials as endorsements of lower court rulings.
It underscores the Court’s selective role in managing its docket and addressing cases of broad constitutional or legal importance.

Question 4

Case: Dred v Scott 1957

Answer 4

Facts:
Dred Scott was an enslaved man owned by Dr. John Emerson, a U.S. Army surgeon. Emerson took Scott to free territories, including Illinois and the Wisconsin Territory, where slavery was prohibited by the Missouri Compromise.
After Emerson’s death, Scott attempted to purchase his freedom but was denied. He filed a lawsuit claiming that his residence in free territories made him a free man.
Procedural History:
Scott initially won his case in a Missouri state court, but the Missouri Supreme Court reversed the decision, reinstating his enslaved status.
Scott then filed a federal lawsuit against Emerson’s widow’s brother, John F.A. Sandford, in the U.S. District Court for Missouri. The court ruled against Scott.
Scott appealed to the U.S. Supreme Court.
Issues:
Was Dred Scott a citizen of the United States and thus eligible to sue in federal court?
Did Scott’s residence in free territories make him a free man?
Was the Missouri Compromise, which prohibited slavery in certain territories, constitutional?
Holding:
Scott was not a citizen: The Court ruled that people of African descent, whether free or enslaved, were not U.S. citizens under the Constitution and could not sue in federal court.
Scott remained enslaved: Living in a free territory did not change Scott’s status as an enslaved person.
Missouri Compromise was unconstitutional: The Court declared that Congress lacked the authority to prohibit slavery in the territories, as it violated slaveholders’ Fifth Amendment rights to property.
Reasoning (Chief Justice Roger B. Taney):
Citizenship:
Taney argued that at the time of the Constitution’s drafting, Black people were not considered part of the political community and thus could not be citizens.
Free Territories:
Scott’s residence in free territories did not emancipate him because Missouri law controlled his status, and Missouri was a slave state.
Missouri Compromise:
By banning slavery in certain territories, Congress infringed on property rights protected by the Fifth Amendment.
Impact:
Legal Consequences:
The decision effectively nullified the Missouri Compromise and heightened sectional tensions by expanding the reach of slavery into free territories.
Political Consequences:
The ruling outraged abolitionists and strengthened the Republican Party’s anti-slavery platform.
It further polarized the nation, contributing to the onset of the Civil War.
Legacy:
Widely condemned as one of the worst Supreme Court decisions in U.S. history.
The decision was effectively overturned by the 13th Amendment (abolishing slavery) and 14th Amendment (granting citizenship to all persons born or naturalized in the U.S.).