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Court Cases that Changed America

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1 Court Cases that Changed America

2 Marbury v. Madison (1803) Facts of the Case
Justice William Marbury was appointed to a federal judge position in the last few hours of John Adam’s presidency The post (job had been created under the Judiciary Act) (an act of Congress) B/c it was a last minute appointment, Marbury was never actually rewarded his job in the Jefferson administration He sues

3 Marbury v. Madison (1803) Decision:
Partly in order to avoid showdown with Jefferson, court rules in favor of Madison (Jefferson’s rep in the case), stating that Judiciary Act of 1789, which gave Marbury his appointment in the first place, was unconstitutional to start with Judiciary Act of 1789 was an act of Congress He does not receive his appointment

4 Marbury v. Madison (1803) So What?
Despite backing down to Jefferson, Court gains powerful tool – Judicial Review Court now has authority to rule whether or not acts of the government are constitutional. A law passed by Congress can be unconstitutional or an act or order of the President can, be as well. Brilliant!

5 McCulloch v. Maryland (1819)
Facts of the case: 1n 1816, Congress chartered (started) the Second Bank of the U.S. A few yrs later the state of MD passed a law that taxed the bank James McCulloch, the teller of the Baltimore branch of the bank, refused to pay the tax Maryland sues him

6 McCulloch v. Maryland (1819)
Decision: Court ruled that Congress (part of the central gov’t) did have the authority to charter a bank – via their authority to collect taxes, borrow money, regulate commerce & raise army/navy Federal Government is supreme and states could not interfere; taxing the bank was interference. a state cannot tax a federal institution Martin v. Hunter's Lessee, 14 U.S. 304 (1816), was a landmark United States Supreme Court case decided on March 20, It was the first case to assert ultimate Supreme Court authority over state courts in matters of federal law. During the American Revolution, the state of Virginia enacted legislation that allowed it to confiscate Loyalists’ property. Here, the original suit was an action of ejectment brought in Virginia state court for the recovery of a parcel of land in the area known as the Northern Neck of Virginia. A declaration in ejectment was served in April, 1791 on the tenants in possession of the land. Denny Fairfax (late Denny Martin) was a British subject who held the land under the devise of the late Thomas Lord Fairfax. Denny Martin was admitted to defend the suit and plead the general issue upon the usual terms of confessing lease, entry, and ouster. Martin agreed to insist that he would assert claim to the title only. The facts being settled in the form of a case agreed to be taken and considered as a special verdict, the court, on consideration thereof, gave judgment in favor of the defendant in ejectment on April 24, From that judgment the plaintiff in ejectment (now defendant in error) appealed to the court of appeals. The Virginia state supreme court upheld the confiscation. It did not do so on the grounds that Virginia law was superior to U.S. treaties, but rather because it argued that its own interpretation of the treaty revealed that the treaty did not, in fact, cover the dispute. On review, the U.S. Supreme Court disagreed with this conclusion, ruling that the treaty did in fact cover the dispute, and remanded the case back to the Virginia Supreme Court, but the Virginia court then argued that the U.S. Supreme Court did not have authority over cases originating in state court. The U.S. Supreme Court reversed the state court’s decision on appeal, ruling that questions of federal law were within its jurisdiction, and thereby establishing its own supremacy in matters of constitutional interpretation. Though Chief Justice John Marshall wrote most of the Supreme Court opinions during his tenure, he did not write this opinion. Marshall instead recused himself from the case for financial reasons because he and his brother had signed a contract with Martin to buy the land in dispute. Justice Joseph Story wrote the decision for a unanimous court. The Virginia Court of Appeals refused to obey the Supreme Court's ruling, however, and unanimously held that Hunter was the proper owner of the tract and that the U.S. Supreme Court lacked authority to review and overturn its decisions. The Virginia court maintained that Section 25 of the 1789 Judiciary Act, which expressly allowed the Supreme Court to review decisions of state supreme courts, was unconstitutional. The court argued that the U.S. Constitution did not provide for such a review in its text, and that the states, as independent governments within the federal system, had final say over federal laws in cases litigated in state courts. On second appeal, the U.S. Supreme Court held that the Constitution did allow the Supreme Court to review state court decisions concerning federal laws (including treaties and the Constitution). Justice Joseph Story wrote the Court's opinion (Chief Justice John Marshall held an interest in Fairfax's land and recused himself from the case). Story first noted that the U.S. Constitution, Article III, implicitly allows Congress to decide whether the Supreme Court may review state decisions of federal law, and that Congress properly authorized such review in passing the Judiciary Act of Story went on to explain that the Constitution does not guarantee the states total independence from the federal government, and in fact is full of restrictions on state power. While state judges are bound to the same U.S. Constitution and laws as are federal judges, the final interpretation of such laws is best left to a single, competent entity -- the U.S. Supreme Court -- and the Virginia court, therefore, was required to enter judgment in favor of Fairfax. Story's logic is hard to resist, for if the states had the power to interpret the Constitution, there would ultimately be as many versions of the Constitution as there were states. Martin v. Hunter's Lessee, stands along side of Marbury v. Madison (1803) in shaping the contours of the federal judiciary and establishing the Supreme Court as the ultimate arbiter of federal law. Martin authorized the second great expansion of the federal judiciary in the Marshall Court era and established the primacy of the federal judiciary over state courts on questions of federal law. In just 40 years, the continued weakening of state power would prompt states like Virginia to secede from the Union. Yet the resulting Civil War would permanently vanquish the notion Martin had already weakened -- that the states are independent governments within the federal system able to disobey and even withdraw their ties with Washington on a whim.

7 McCulloch v. Maryland (1819)
So What: Established doctrine of implied powers, providing Congress with more flexibility to enact legislation (legislation which established the Bank in the first place). Reaffirmed supremacy of Federal government.

8 Gibbons v. Ogden (1824) Facts of the Case:
A New York state law gave two individuals the exclusive right to operate steamboats on waters within state jurisdiction. Laws like this one were duplicated elsewhere which led to friction as some states would require foreign (out-of-state) boats to pay substantial fees for navigation privileges. In this case a steamboat owner who did business between New York and New Jersey challenged the monopoly that New York had granted, which forced him to obtain a special operating permit from the state to navigate on its waters.

9 Gibbons v. Ogden (1824) Decision:
The Court ruled the monopoly unconstitutional. Constitution grants Congress the power to regulate interstate commerce – along coast or on waterways between states. States could regulate trade ONLY within their own borders. Facts of the Case:  A New York state law gave two individuals the exclusive right to operate steamboats on waters within state jurisdiction. Laws like this one were duplicated elsewhere which led to friction as some states would require foreign (out-of-state) boats to pay substantial fees for navigation privileges. In this case a steamboat owner who did business between New York and New Jersey challenged the monopoly that New York had granted, which forced him to obtain a special operating permit from the state to navigate on its waters. Question:  Did the State of New York exercise authority in a realm reserved exclusively to Congress, namely, the regulation of interstate commerce? Conclusion:  The Court found that New York's licensing requirement for out-of-state operators was inconsistent with a congressional act regulating the coasting trade. The New York law was invalid by virtue of the Supremacy Clause. In his opinion, Chief Justice Marshall developed a clear definition of the word commerce, which included navigation on interstate waterways. He also gave meaning to the phrase "among the several states" in the Commerce Clause. Marshall's was one of the earliest and most influential opinions concerning this important clause. He concluded that regulation of navigation by steamboat operators and others for purposes of conducting interstate commerce was a power reserved to and exercised by the Congress.

10 Gibbons v. Ogden (1824) So What?
Gave Congress the right to regulate interstate commerce. Interstate commerce clause (along with Necessary & Proper Clause) are the major vehicle for expanding federal power. Facts of the Case:  A New York state law gave two individuals the exclusive right to operate steamboats on waters within state jurisdiction. Laws like this one were duplicated elsewhere which led to friction as some states would require foreign (out-of-state) boats to pay substantial fees for navigation privileges. In this case a steamboat owner who did business between New York and New Jersey challenged the monopoly that New York had granted, which forced him to obtain a special operating permit from the state to navigate on its waters. Question:  Did the State of New York exercise authority in a realm reserved exclusively to Congress, namely, the regulation of interstate commerce? Conclusion:  The Court found that New York's licensing requirement for out-of-state operators was inconsistent with a congressional act regulating the coasting trade. The New York law was invalid by virtue of the Supremacy Clause. In his opinion, Chief Justice Marshall developed a clear definition of the word commerce, which included navigation on interstate waterways. He also gave meaning to the phrase "among the several states" in the Commerce Clause. Marshall's was one of the earliest and most influential opinions concerning this important clause. He concluded that regulation of navigation by steamboat operators and others for purposes of conducting interstate commerce was a power reserved to and exercised by the Congress.

11 (until they change what they say it says)
Moral of the Day! The Constitution says…. …what the Supreme Court says it says. (until they change what they say it says) Facts of the Case:  A New York state law gave two individuals the exclusive right to operate steamboats on waters within state jurisdiction. Laws like this one were duplicated elsewhere which led to friction as some states would require foreign (out-of-state) boats to pay substantial fees for navigation privileges. In this case a steamboat owner who did business between New York and New Jersey challenged the monopoly that New York had granted, which forced him to obtain a special operating permit from the state to navigate on its waters. Question:  Did the State of New York exercise authority in a realm reserved exclusively to Congress, namely, the regulation of interstate commerce? Conclusion:  The Court found that New York's licensing requirement for out-of-state operators was inconsistent with a congressional act regulating the coasting trade. The New York law was invalid by virtue of the Supremacy Clause. In his opinion, Chief Justice Marshall developed a clear definition of the word commerce, which included navigation on interstate waterways. He also gave meaning to the phrase "among the several states" in the Commerce Clause. Marshall's was one of the earliest and most influential opinions concerning this important clause. He concluded that regulation of navigation by steamboat operators and others for purposes of conducting interstate commerce was a power reserved to and exercised by the Congress.

12 Cohens v. Virginia (1821) So What?
Reasserted federal judicial authority over state courts. Supreme Court argued that when states ratified the Constitution, they gave up some sovereignty to federal courts. Facts of the Case:  An act of Congress authorized the operation of a lottery in the District of Columbia. The Cohen brothers proceeded to sell D.C. lottery tickets in the state of Virginia, violating state law. State authorities tried and convicted the Cohens, and then declared themselves to be the final arbiters of disputes between the states and the national government. Question:  Did the Supreme Court have the power under the Constitution to review the Virginia Supreme Court's ruling? Conclusion:  In a unanimous decision, the Court held that the Supreme Court had jurisdiction to review state criminal proceedings. Chief Justice Marshall wrote that the Court was bound to hear all cases that involved constitutional questions, and that this jurisdiction was not dependent on the identity of the parties in the cases. Marshall argued that state laws and constitutions, when repugnant to the Constitution and federal laws, were "absolutely void." After establishing the Court's jurisdiction, Marshall declared the lottery ordinance a local matter and concluded that the Virginia court was correct to fine the Cohens brothers for violating Virginia law.

13 Fletcher v. Peck (1810) Decision:
Court held that since the estate had been legally "passed into the hands of a purchaser for a valuable consideration," the Georgia legislature could not take away the land or invalidate the contract. The Court held that laws annulling contracts or grants made by previous legislative acts were constitutionally impermissible – regardless of intention when passed. Fletcher v. Peck, 10 U.S. 87 (1810), was a landmark United States Supreme Court decision. It was one of the first cases in which the Supreme Court ruled a state law unconstitutional. In the course of the westward push for the control of Indian lands, the state of Georgia took from the Indians a 35-million-acre (140,000 km2) region in the Yazoo River area known as the Yazoo Lands. This land later became the states of Alabama and Mississippi. In 1795, the Georgia legislature divided the area into four tracts. The state then sold the tracts to four separate land development companies for a modest total price of $500,000, i.e. about 1.4 cents per acre ($3.46/km2), a good deal even at 1790s prices. The Georgia legislature overwhelmingly approved this land grant, known as the Yazoo Land Act of 1795. It was revealed that the Yazoo Land Act sale to private speculators had been approved in return for bribes. Voters rejected most of the incumbents in the next election, and the next legislature, reacting to the public outcry, repealed the law and voided transactions made under it. John Peck had purchased land that had previously been sold under the 1795 act. Peck sold this land to Robert Fletcher and in 1803, Fletcher brought suit against Peck, claiming that he did not have clear title to the land when he sold it. The case reached the Supreme Court, which in a unanimous decision ruled that the state legislature's repeal of the law was unconstitutional. The opinion, written by John Marshall, argued that the sale was a binding contract, which according to Article I, Section 10, Clause I (the Contract Clause) of the Constitution cannot be invalidated, even if illegally secured. Today the ruling further protects property rights against popular pressures, and is the earliest case of the Court asserting its right to invalidate state laws conflicting with the Constitution. Question:  Could the contract between Fletcher and Peck be invalidated by an act of the Georgia legislature? Conclusion:  In a unanimous opinion, the Court held that since the estate had been legally "passed into the hands of a purchaser for a valuable consideration," the Georgia legislature could not take away the land or invalidate the contract. Noting that the Constitution did not permit bills of attainder or ex post facto laws, the Court held that laws annulling contracts or grants made by previous legislative acts were constitutionally impermissible.

14 Fletcher v. Peck (1810) So What?
1st: protected contracts from state interference. 2nd: Court could overturn state laws that opposed specific provisions of the Constitution Contract Clause: Art I, sect 10, clause 1. It states: “ No State shall…pass any Bill of Attainder, ex post facto Law, or Law impairing the Obligation of Contracts… Fletcher v. Peck, 10 U.S. 87 (1810), was a landmark United States Supreme Court decision. It was one of the first cases in which the Supreme Court ruled a state law unconstitutional. In the course of the westward push for the control of Indian lands, the state of Georgia took from the Indians a 35-million-acre (140,000 km2) region in the Yazoo River area known as the Yazoo Lands. This land later became the states of Alabama and Mississippi. In 1795, the Georgia legislature divided the area into four tracts. The state then sold the tracts to four separate land development companies for a modest total price of $500,000, i.e. about 1.4 cents per acre ($3.46/km2), a good deal even at 1790s prices. The Georgia legislature overwhelmingly approved this land grant, known as the Yazoo Land Act of 1795. It was revealed that the Yazoo Land Act sale to private speculators had been approved in return for bribes. Voters rejected most of the incumbents in the next election, and the next legislature, reacting to the public outcry, repealed the law and voided transactions made under it. John Peck had purchased land that had previously been sold under the 1795 act. Peck sold this land to Robert Fletcher and in 1803, Fletcher brought suit against Peck, claiming that he did not have clear title to the land when he sold it. The case reached the Supreme Court, which in a unanimous decision ruled that the state legislature's repeal of the law was unconstitutional. The opinion, written by John Marshall, argued that the sale was a binding contract, which according to Article I, Section 10, Clause I (the Contract Clause) of the Constitution cannot be invalidated, even if illegally secured. Today the ruling further protects property rights against popular pressures, and is the earliest case of the Court asserting its right to invalidate state laws conflicting with the Constitution. Question:  Could the contract between Fletcher and Peck be invalidated by an act of the Georgia legislature? Conclusion:  In a unanimous opinion, the Court held that since the estate had been legally "passed into the hands of a purchaser for a valuable consideration," the Georgia legislature could not take away the land or invalidate the contract. Noting that the Constitution did not permit bills of attainder or ex post facto laws, the Court held that laws annulling contracts or grants made by previous legislative acts were constitutionally impermissible.

15 Martin v. Hunter's Lessee (1816)
So What? Court could accept appeals from state courts that involve federal laws or treaties. More importantly, it asserted the Supreme Court’s sovereignty over state courts, rejecting VA’s claim that they were equal sovereigns. Martin v. Hunter's Lessee, 14 U.S. 304 (1816), was a landmark United States Supreme Court case decided on March 20, It was the first case to assert ultimate Supreme Court authority over state courts in matters of federal law. During the American Revolution, the state of Virginia enacted legislation that allowed it to confiscate Loyalists’ property. Here, the original suit was an action of ejectment brought in Virginia state court for the recovery of a parcel of land in the area known as the Northern Neck of Virginia. A declaration in ejectment was served in April, 1791 on the tenants in possession of the land. Denny Fairfax (late Denny Martin) was a British subject who held the land under the devise of the late Thomas Lord Fairfax. Denny Martin was admitted to defend the suit and plead the general issue upon the usual terms of confessing lease, entry, and ouster. Martin agreed to insist that he would assert claim to the title only. The facts being settled in the form of a case agreed to be taken and considered as a special verdict, the court, on consideration thereof, gave judgment in favor of the defendant in ejectment on April 24, From that judgment the plaintiff in ejectment (now defendant in error) appealed to the court of appeals. The Virginia state supreme court upheld the confiscation. It did not do so on the grounds that Virginia law was superior to U.S. treaties, but rather because it argued that its own interpretation of the treaty revealed that the treaty did not, in fact, cover the dispute. On review, the U.S. Supreme Court disagreed with this conclusion, ruling that the treaty did in fact cover the dispute, and remanded the case back to the Virginia Supreme Court, but the Virginia court then argued that the U.S. Supreme Court did not have authority over cases originating in state court. The U.S. Supreme Court reversed the state court’s decision on appeal, ruling that questions of federal law were within its jurisdiction, and thereby establishing its own supremacy in matters of constitutional interpretation. Though Chief Justice John Marshall wrote most of the Supreme Court opinions during his tenure, he did not write this opinion. Marshall instead recused himself from the case for financial reasons because he and his brother had signed a contract with Martin to buy the land in dispute. Justice Joseph Story wrote the decision for a unanimous court. The Virginia Court of Appeals refused to obey the Supreme Court's ruling, however, and unanimously held that Hunter was the proper owner of the tract and that the U.S. Supreme Court lacked authority to review and overturn its decisions. The Virginia court maintained that Section 25 of the 1789 Judiciary Act, which expressly allowed the Supreme Court to review decisions of state supreme courts, was unconstitutional. The court argued that the U.S. Constitution did not provide for such a review in its text, and that the states, as independent governments within the federal system, had final say over federal laws in cases litigated in state courts. On second appeal, the U.S. Supreme Court held that the Constitution did allow the Supreme Court to review state court decisions concerning federal laws (including treaties and the Constitution). Justice Joseph Story wrote the Court's opinion (Chief Justice John Marshall held an interest in Fairfax's land and recused himself from the case). Story first noted that the U.S. Constitution, Article III, implicitly allows Congress to decide whether the Supreme Court may review state decisions of federal law, and that Congress properly authorized such review in passing the Judiciary Act of Story went on to explain that the Constitution does not guarantee the states total independence from the federal government, and in fact is full of restrictions on state power. While state judges are bound to the same U.S. Constitution and laws as are federal judges, the final interpretation of such laws is best left to a single, competent entity -- the U.S. Supreme Court -- and the Virginia court, therefore, was required to enter judgment in favor of Fairfax. Story's logic is hard to resist, for if the states had the power to interpret the Constitution, there would ultimately be as many versions of the Constitution as there were states. Martin v. Hunter's Lessee, stands along side of Marbury v. Madison (1803) in shaping the contours of the federal judiciary and establishing the Supreme Court as the ultimate arbiter of federal law. Martin authorized the second great expansion of the federal judiciary in the Marshall Court era and established the primacy of the federal judiciary over state courts on questions of federal law. In just 40 years, the continued weakening of state power would prompt states like Virginia to secede from the Union. Yet the resulting Civil War would permanently vanquish the notion Martin had already weakened -- that the states are independent governments within the federal system able to disobey and even withdraw their ties with Washington on a whim.

16 Martin v. Hunter's Lessee (1816)
Decision: VA Supreme Court upheld the confiscation, not on the grounds that VA law was superior to US treaties, but because it argued that its own interpretation of the treaty revealed that the treaty did not, in fact, cover the dispute. The US Supreme Court disagreed, and remanded the case back to VA S.C., VA argued that the US S.C. did not have authority over cases originating in state court. The US S.C. reversed VA’s decision on appeal, ruling that questions of federal law were within its jurisdiction, and thereby establishing supremacy in matters of constitutional interpretation. Martin v. Hunter's Lessee, 14 U.S. 304 (1816), was a landmark United States Supreme Court case decided on March 20, It was the first case to assert ultimate Supreme Court authority over state courts in matters of federal law. During the American Revolution, the state of Virginia enacted legislation that allowed it to confiscate Loyalists’ property. Here, the original suit was an action of ejectment brought in Virginia state court for the recovery of a parcel of land in the area known as the Northern Neck of Virginia. A declaration in ejectment was served in April, 1791 on the tenants in possession of the land. Denny Fairfax (late Denny Martin) was a British subject who held the land under the devise of the late Thomas Lord Fairfax. Denny Martin was admitted to defend the suit and plead the general issue upon the usual terms of confessing lease, entry, and ouster. Martin agreed to insist that he would assert claim to the title only. The facts being settled in the form of a case agreed to be taken and considered as a special verdict, the court, on consideration thereof, gave judgment in favor of the defendant in ejectment on April 24, From that judgment the plaintiff in ejectment (now defendant in error) appealed to the court of appeals. The Virginia state supreme court upheld the confiscation. It did not do so on the grounds that Virginia law was superior to U.S. treaties, but rather because it argued that its own interpretation of the treaty revealed that the treaty did not, in fact, cover the dispute. On review, the U.S. Supreme Court disagreed with this conclusion, ruling that the treaty did in fact cover the dispute, and remanded the case back to the Virginia Supreme Court, but the Virginia court then argued that the U.S. Supreme Court did not have authority over cases originating in state court. The U.S. Supreme Court reversed the state court’s decision on appeal, ruling that questions of federal law were within its jurisdiction, and thereby establishing its own supremacy in matters of constitutional interpretation. Though Chief Justice John Marshall wrote most of the Supreme Court opinions during his tenure, he did not write this opinion. Marshall instead recused himself from the case for financial reasons because he and his brother had signed a contract with Martin to buy the land in dispute. Justice Joseph Story wrote the decision for a unanimous court. The Virginia Court of Appeals refused to obey the Supreme Court's ruling, however, and unanimously held that Hunter was the proper owner of the tract and that the U.S. Supreme Court lacked authority to review and overturn its decisions. The Virginia court maintained that Section 25 of the 1789 Judiciary Act, which expressly allowed the Supreme Court to review decisions of state supreme courts, was unconstitutional. The court argued that the U.S. Constitution did not provide for such a review in its text, and that the states, as independent governments within the federal system, had final say over federal laws in cases litigated in state courts. On second appeal, the U.S. Supreme Court held that the Constitution did allow the Supreme Court to review state court decisions concerning federal laws (including treaties and the Constitution). Justice Joseph Story wrote the Court's opinion (Chief Justice John Marshall held an interest in Fairfax's land and recused himself from the case). Story first noted that the U.S. Constitution, Article III, implicitly allows Congress to decide whether the Supreme Court may review state decisions of federal law, and that Congress properly authorized such review in passing the Judiciary Act of Story went on to explain that the Constitution does not guarantee the states total independence from the federal government, and in fact is full of restrictions on state power. While state judges are bound to the same U.S. Constitution and laws as are federal judges, the final interpretation of such laws is best left to a single, competent entity -- the U.S. Supreme Court -- and the Virginia court, therefore, was required to enter judgment in favor of Fairfax. Story's logic is hard to resist, for if the states had the power to interpret the Constitution, there would ultimately be as many versions of the Constitution as there were states. Martin v. Hunter's Lessee, stands along side of Marbury v. Madison (1803) in shaping the contours of the federal judiciary and establishing the Supreme Court as the ultimate arbiter of federal law. Martin authorized the second great expansion of the federal judiciary in the Marshall Court era and established the primacy of the federal judiciary over state courts on questions of federal law. In just 40 years, the continued weakening of state power would prompt states like Virginia to secede from the Union. Yet the resulting Civil War would permanently vanquish the notion Martin had already weakened -- that the states are independent governments within the federal system able to disobey and even withdraw their ties with Washington on a whim.

17 Cohens v. Virginia (1821) Decision:
Court upheld conviction of Cohen brothers. The larger issue: actually reviewing state court cases. The S.C. claimed full appellate jurisdiction over any case tried before a state court. VA decided that this was unacceptable & declared the decision the SC made null & void, even though it had upheld the previous conviction, because VA felt the ruling limited states' rights. Facts of the Case:  An act of Congress authorized the operation of a lottery in the District of Columbia. The Cohen brothers proceeded to sell D.C. lottery tickets in the state of Virginia, violating state law. State authorities tried and convicted the Cohens, and then declared themselves to be the final arbiters of disputes between the states and the national government. Question:  Did the Supreme Court have the power under the Constitution to review the Virginia Supreme Court's ruling? Conclusion:  In a unanimous decision, the Court held that the Supreme Court had jurisdiction to review state criminal proceedings. Chief Justice Marshall wrote that the Court was bound to hear all cases that involved constitutional questions, and that this jurisdiction was not dependent on the identity of the parties in the cases. Marshall argued that state laws and constitutions, when repugnant to the Constitution and federal laws, were "absolutely void." After establishing the Court's jurisdiction, Marshall declared the lottery ordinance a local matter and concluded that the Virginia court was correct to fine the Cohens brothers for violating Virginia law.

18 Gibbons v. Ogden (1824) Facts of the Case:
A New York state law gave two individuals the exclusive right to operate steamboats on waters within state jurisdiction. Laws like this one were duplicated elsewhere which led to friction as some states would require foreign (out-of-state) boats to pay substantial fees for navigation privileges. In this case a steamboat owner who did business between New York and New Jersey challenged the monopoly that New York had granted, which forced him to obtain a special operating permit from the state to navigate on its waters. Question:  Did the State of New York exercise authority in a realm reserved exclusively to Congress, namely, the regulation of interstate commerce? Conclusion:  The Court found that New York's licensing requirement for out-of-state operators was inconsistent with a congressional act regulating the coasting trade. The New York law was invalid by virtue of the Supremacy Clause. In his opinion, Chief Justice Marshall developed a clear definition of the word commerce, which included navigation on interstate waterways. He also gave meaning to the phrase "among the several states" in the Commerce Clause. Marshall's was one of the earliest and most influential opinions concerning this important clause. He concluded that regulation of navigation by steamboat operators and others for purposes of conducting interstate commerce was a power reserved to and exercised by the Congress.


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