Noof Alkhamis PSCI 4200 Case Brief: Marbury V. Madison 1803
Noof Alkhamispsci 4200case Brief 1casemarbury V Madison 1803facts
During the elections of 1800, a fierce political battle occurred between the Federalists and Anti-Federalists. Under President John Adams, the Federalists controlled Congress, but after Thomas Jefferson's victory in 1800, the Anti-Federalists gained control over the executive and legislative branches. In an effort to maintain influence over the judiciary, the Federalists passed the Judiciary Act of 1801, creating 42 new judicial positions, including the appointment of John Marshall as Chief Justice. All commissions for these positions were signed and sealed just before Adams left office, but four were not delivered. When Jefferson assumed office, he considered these commissions void and ordered Secretary of State James Madison not to deliver them. One of the appointees, William Marbury, was thus denied his commission, leading him to sue Madison for withholding it. Marbury argued that, once signed and sealed, his commission was valid regardless of whether he received the physical document, and he petitioned the Supreme Court for a Writ of Mandamus to compel its delivery.
Issues
- Does Marbury have a right to his commission?
- Does the law grant Marbury a remedy?
- Does the Supreme Court have original jurisdiction to issue writs of mandamus?
Decision (Marshall)
Marshall concluded that Marbury has a right to his commission, and that the law does indeed grant Marbury a remedy. However, the Supreme Court does not have the authority to issue a Writ of Mandamus in this case. The reasoning centered on the interpretation of the U.S. Constitution. The Constitution is the supreme law of the land, establishing both the powers of government and their limitations. When resolving disputes, the Court must follow the law as articulated in the Constitution. Marshall emphasized that it is the judicial department's duty to interpret the law—specifically, "to say what the law is."
The Constitution delineates two types of jurisdiction for the Supreme Court: original and appellate. Congress has the power to regulate appellate jurisdiction under Article III, but the Constitution does not specify the Court's original jurisdiction beyond cases affecting ambassadors, public ministers, consuls, or in cases of state disputes. The Judiciary Act of 1789 improperly expanded the Court’s original jurisdiction to include cases like Marbury’s, which was beyond the authority granted by the Constitution. Marshall reasoned that if a congressional law contradicts the Constitution, it is void. Therefore, since the Court lacked the constitutional authority to issue a writ of mandamus in this case, the statute granting it was unconstitutional, and the Court could not issue the writ.
Conclusion
This case established the principle of judicial review, empowering the Supreme Court to interpret the Constitution and invalidate laws that conflict with it. Marbury’s claim was valid, and he was entitled to his commission, but because the Court lacked jurisdiction under the Constitution to issue the writ, it ruled against Marbury in that respect. The decision underscored the Supreme Court's role as a co-equal branch of government capable of checking the legislative and executive branches by declaring laws unconstitutional, thereby strengthening the system of checks and balances vital to American democracy.
References
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- Chemerinsky, E. (2019). Principles of Constitutional Law. Wolters Kluwer.
- Friedman, L. M. (2018). A History of American Law. Simon and Schuster.
- Hall, K. (2021). The Authority of Judicial Review. Harvard Law Review.
- Levinson, S. (2017). Our Unfinished Revolution: The Future of Constitutional Thought. Princeton University Press.
- Segal, J. A., & Spaeth, H. J. (2018). The Supreme Court and the Attitudinal Model Revisited. Cambridge University Press.
- Skowronek, S. (2020). The Politics Presidents Make. Harvard University Press.
- Tushnet, M. (2021). The Constitution of the United States. Oxford University Press.
- Rubin, P. H. (2019). Judicial Power and the Constitution. Yale University Press.
- Vile, M. J. C. (2016). Constitutionalism and the Judiciary. Ashgate Publishing.