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Marbury v. Madison Case Brief
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Case Brief Summary & Legal Analysis
tl;dr: The Supreme Court established the principle of judicial review, asserting its power to declare congressional acts unconstitutional. While Marbury had a right to his commission, the Court lacked original jurisdiction to issue a writ of mandamus.
Legal Significance: This landmark case established the doctrine of judicial review, empowering the Supreme Court to invalidate laws conflicting with the U.S. Constitution, thereby defining the judiciary’s role in the separation of powers.
Case Facts & Court Holding
Key Facts & Case Background
In the final days of President John Adams’s administration, William Marbury was appointed as a Justice of the Peace for the District of Columbia. His commission was signed by President Adams and sealed by the acting Secretary of State, John Marshall (who was also Chief Justice). However, the commission was not delivered before Adams left office. The new President, Thomas Jefferson, instructed his Secretary of State, James Madison, to withhold the undelivered commissions, including Marbury’s. Marbury filed suit directly in the Supreme Court, seeking a writ of mandamus to compel Madison to deliver his commission. He based his claim for original jurisdiction in the Supreme Court on Section 13 of the Judiciary Act of 1789, which purported to grant the Court the power to issue writs of mandamus in original jurisdiction to persons holding office under the authority of the United States. The Court considered three questions: (1) Has the applicant a right to the commission he demands? (2) If he has a right, and that right has been violated, do the laws of his country afford him a remedy? (3) If they do afford him a remedy, is it a mandamus issuing from this court?
Court Holding & Legal Precedent
Issue: Does the Supreme Court have the authority under Article III of the Constitution to issue a writ of mandamus compelling the Secretary of State to deliver a commission when such authority is granted by an Act of Congress but potentially conflicts with the constitutional grant of original jurisdiction?
The Court held that Marbury had a vested legal right to his commission once it was signed by the President and sealed by the Secretary of State (Opinion, p. *162). The laws afforded him a remedy for the violation of this right (Opinion, p. *168). However, the Supreme Court lacked the constitutional authority to issue a writ of mandamus in this case as an exercise of original jurisdiction. Section 13 of the Judiciary Act of 1789, by attempting to grant the Supreme Court original jurisdiction to issue writs of mandamus beyond the categories enumerated in Article III, § 2, was unconstitutional and therefore void (Opinion, p. *176).
IRAC Legal Analysis
Legal Issue
Does the Supreme Court have the authority under Article III of the Constitution to issue a writ of mandamus compelling the Secretary of State to deliver a commission when such authority is granted by an Act of Congress but potentially conflicts with the constitutional grant of original jurisdiction?
Conclusion
Marbury v. Madison established the principle of judicial review, affirming the Supreme Court’s authority to interpret the Constitution and invalidate congressional acts that conflict with it, a cornerstone of American constitutional law.
Legal Rule
The Constitution is the supreme law of the land, and any legislative act repugnant to the Constitution is void. It is emphatically the province and duty of the judicial department to say what the law is, including the power to review acts of Congress and declare them unconstitutional if they conflict with the Constitution. (U.S. Const. art. III, § 2; U.S. Const. art. VI, cl. 2). Congress cannot expand the Supreme Court’s original jurisdiction beyond that specified in Article III.
Legal Analysis
Chief Justice Marshall, writing for a unanimous Court, first determined that Marbury’s appointment was complete when his commission was signed by the President and sealed by the Secretary of State. The delivery of the commission was a ministerial act, not a discretionary one, and withholding it violated Marbury’s vested legal right (Opinion, pp. *157-162). The Court affirmed that for every legal right, there is a legal remedy (Opinion, p. *163). However, the crucial part of the opinion addressed the Court’s jurisdiction. Article III, Section 2 of the Constitution explicitly defines the Supreme Court’s original jurisdiction, limiting it to cases affecting ambassadors, other public ministers and consuls, and those in which a state shall be a party. In all other cases, the Court has appellate jurisdiction. The Court reasoned that Section 13 of the Judiciary Act of 1789 attempted to expand this constitutionally defined original jurisdiction by authorizing the Court to issue writs of mandamus to public officers in an original proceeding (Opinion, p. *174). Marshall argued that if Congress could alter the Court’s original jurisdiction, then the constitutional enumeration would be ‘form without substance’ (Opinion, p. *174). This led to the foundational assertion that ‘an act of the legislature, repugnant to the constitution, is void’ (Opinion, p. *177). The Court declared it ‘emphatically the province and duty of the judicial department to say what the law is’ (Opinion, p. *177). This includes the power to interpret the Constitution and to refuse to enforce laws that conflict with it, thereby establishing the principle of judicial review. The oath taken by judges to support the Constitution further underscored this duty (Opinion, p. *180).
Flash-to-Full Case Opinions
Flash Summary
- Established the principle of judicial review: the Supreme Court’s power to declare acts of Congress unconstitutional.
- Held that Section 13 of the Judiciary Act of 1789 was unconstitutional for attempting to expand the Supreme Court’s original jurisdiction beyond Article III’s limits.
- Affirmed that “It is emphatically the province and duty of the judicial department to say what the law is.”