Marbury v. Madison
5 U.S. 137 (1803)
Constitutional Topic Areas:
Judicial Review, Separation of Powers, Article III, Congressional/Judicial Powers, Article VI Clause 2 ‘Supremacy Clause’, Federalism
Case Facts:
Before departing office, 2nd President John Adams attempted to pack the courts with his party members in his bout of “midnight appointments.” Paperwork appointing William Marbury as a federal Judge had been officially signed and sealed, however, had not been delivered by Jefferson’s assumption of the office. Jefferson mandated Secretary of State James Madison to withhold Marbury’s commission. Marbury then petitioned the Supreme Court to issue a writ of mandamus to mandate Madison to deliver the commission under the Judiciary Act of 1789.
Questions:
1. Does Marbury have a right to his commission?
2. Is a writ of mandamus the proper method of legal remedy?
3. Can the Supreme Court issue this legal remedy?
Holding:
1. Yes
2. Yes
3. No
Legal Reasoning: Chief Justice J. Marshall (Unanimous)
1. Since Marbury’s commission was signed and sealed, Marbury is entitled to his commission
2. Because of Marbury’s entitlement to the commission, denial violates law and government is responsible to remedy violation of law and the writ of mandamus is the proper remedy
3. Because the Supreme Court has no original jurisdiction for this case, Marbury would have to start at a lower court and appeal up to the Supreme Court first
4. Congress can only limit the Supreme Court’s appellate jurisdiction as Article III of the Constitution fixes the Supreme Court’s original jurisdiction. This lead to a portion of the Judiciary Act of 1789 being stricken down as unconstitutional, as the law effectively changed the Supreme Court’s original jurisdiction. This then left the Supreme Court without jurisdiction to hear Marbury’s case, thus not being able to issue a legal remedy through a writ of mandamus
Significance:
The principle of Judicial Review is established during Marbury v. Madison, defined as the power for the Supreme Court to strike down any law in violation of the Constitution. Explicitly gives the Supreme Court the power to interpret the Constitution
Reflection:
As President Jefferson tried to protect the courts from his opposing party’s influence, he ultimately violated Marbury’s rights pertaining to his commission. As a result, the Judiciary branch ended up gaining power it had not possessed previously. Furthermore, even though the Supreme Court had ruled Marbury indeed did deserve his commission, it lacked the jurisdiction to actually give it to him. Jefferson then ignored the Court’s suggestion to give him his commission, but Marbury would have gotten it if he then filed suit in a court with proper jurisdiction. Overall, Marbury broadened the power of the federal government
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