Marbury v. Madison Case Brief Summary

[Music] article 3 of the us constitution established the united states supreme court it is the highest court in the american judicial system and it possesses immense power it reviews cases under its appellate jurisdiction as they move up from the lower courts and less frequently it decides matters by its original jurisdiction it even has the power to render null and void both state and federal legislation when those laws run afoul of the constitution that last concept falls under judicial review however the constitution that created the court did not expressly grant that power to it so the question arises how did the court obtain what is arguably its most powerful tool my name is matthew collum and here online history we're going to examine the landmark case of marbury b madison we will see how it created judicial review and how that concept made the supreme court truly co-equal to the congress and the presidency before we jump into the case itself we need some historical background to provide some context to the court's decision in 1800 president john adams was running for reelection against his own vice president thomas jefferson both camps fought hard during this race four years earlier in 1796 adams had narrowly defeated jefferson and in those days the defeated presidential candidate served as the victorious president's vp but this was not just a choice between two executives who really disliked each other no this was actually a clash between two political parties with hugely different ideas of what america should be not much has changed on one hand adam's federalist party embraced a robust and centralized federal government for instance it was pro-business it sought a strong military and advocated for better relations with the british on the other hand jefferson's democratic republicans advocated for a decentralized federal authority they embraced state authority and distrusted centralized power of any stripe they viewed the federalists as elitists as supporters as america's business aristocracy they also favored france over great britain ultimately in the elections of 1800 the federalists lost both the presidency and the congress to the democratic republicans now at that time presidential inaugurations took place in march following the election year not in january as they do today however much like today adams realized that by controlling the courts his outgoing party could continue to exert a tremendous amount of influence even if they were no longer the dominant party in congress nor re-elected to the presidency enter the so-called midnight judges as late as early march 1801 just a few days before his term was to expire adams nominated and the federalist dominated senate approved almost 60 judges to embed federalist supporters and to the federal judiciary now among those named was mr william marbury marbury lived in annapolis he was a successful financier and an ardent federalist although not a judge adams appointed marbury as a justice of the peace which was a kind of judicial officer to preside in the district of columbia however adams administration did not deliver marbury's commission to him before the president's term ended chief justice john marshall the justice who would write the opinion in marbury b madison was until the very end of adam's administration also the secretary of state it was his office's responsibility to deliver those commissions and he worked to do so until the very end of adam's term it is here where the facts of the case start to come into play thomas jefferson and his democratic republicans took office on march 4th of 1801 jefferson and his supporters were aghast at adam's midnight judges and they did everything they could to undo his actions this included passing legislation that for the purposes of this video is somewhat beyond our scope however what is firmly within our wheelhouse is this jefferson's secretary of state james madison was legally bound to deliver adams signed commissions to the judicial officials adams appointed but who had not yet received their commissions now this included marbury's commission secretary madison however in line with his boss's opinion on the whole matter refused to deliver the commission thus keeping marbury from assuming his post now later that year later 1801 marbury filed a lawsuit with the supreme court he petitioned the court for a writ of mandamus to compel secretary madison to deliver his commission now two things one you may be wondering what a writ of mandamus is and two you may also be wondering how it is that marbury got his case into the supreme court without first petitioning a lower court well let's answer both of those questions a writ of mandamus is simply a legal mechanism compelling action a petitioner can ask a court to compel someone usually a government official to complete some task or action that the official was already bound by the law to do now they can do this by issuing that rid of mandamus importantly section 13 of the judiciary act of 1789 empowered the court to do just that now we'll discuss that legislation in a little bit more detail a little later in the video section 13 is also what enabled marbury to plead his case directly to the court in the first place section 13 granted the court the power to issue ritz and mandamus and made them part of its original jurisdiction simply put section 13 enabled marbury to petition the court for a writ and it's why he did not have to first petition a lower court to have the case reviewed under its appellate jurisdiction in 1803 the court took up marbury's case the two-year delay was the product of democratic republican political machination and back and forth in the congress that sought to undo much of atoms in the federalist moves regarding the judiciary chief justice john marshall himself a federalist wrote the 26-page opinion identifying three issues for the court to consider and i'll quote them directly one has the applicant a right to the commission he demanded two if he has a right and that right has been violated do the laws of his country afford him a remedy and lastly three if they do afford him a remedy is it a mandamus issuing from the court now issues one and two were really stepping stones to answer the true issue chief justice marshall had identified in the case on its face issue three concerned whether the court could issue the writ of mandamus marbury sought but a deeper reading of the case revealed a concern over jurisdiction and the constitutionality of section 13. without being too tried about it the specifics surrounding the court's holdings regarding issues one and two aren't too terribly important to the legacy of marbury b madison the court's findings on those issues can be summed up as yes marbury had both a legal right to the commission and u.s law did provide a remedy for him but it is in the court's reasoning and holding concerning issue 3 where we find why this case is so important the court answered issue 3 by examining in this one two sub-issues one whether a mandamus was the appropriate remedy and two whether the court had the power to issue one as to sub-issue one the court held that the most appropriate remedy under u.s law was a written mandamus case law and historical precedent both under english and american common law supported that outcome now sub-issue 2 concerned the power of the court to issue that writ of mandemus essentially it considered whether the court could properly exercise that power article 3 section 1 of the constitution established the supreme court and empowered the congress to create such inferior courts as may be necessary congress's judiciary act of 1789 built upon that constitutional foundation and established the lower courts comprising america's federal judiciary as we said section 13 of the act empowered the court to issue writs at mandamus chief justice marshall quoted that section in the opinion stating that quote the judiciary act of 1789 authorized the supreme court to issue writs of mandamus in cases warranted by the principles and usages of law to any courts appointed or persons holding office under the authority of the united states however despite this grant of power by the congress the court held that this congressional expansion of its powers had in fact exceeded the limits placed upon it by the constitution as we touched on the provisions set forth in article 3 of the constitution established the court and permitted congress to establish its lower courts if necessary but it also enumerated the court's powers and delineated the court's original and appellate jurisdictions article 3 section 2 clause 2 of the constitution expressly stated that in all cases affecting ambassadors other public ministers and consuls and those in which a state shall be a party the supreme court shall have original jurisdiction on this sub-issue with regard to whether the court could in fact issue a writ of mandamus under its original jurisdiction the court concluded that issuing that mandamus was only possible when the court addressed a case brought to it under its appellate jurisdiction the constitution had expressly stated to which subjects the court's original jurisdiction applied and issuing a writ of mandamus was not one of them and so in effect section 13 of the 1789 act stood in conflict with the constitution's express provisions the court in one of the opinions most famous passages wrote that quote it is emphatically the province and duty of the judicial department to say what the law is those who apply the rule to particular cases must of necessity expound and interpret that rule if two laws conflict with each other the court must decide on the operation of each and to that end the court did decide it held that section 13 of the 1789 act was unconstitutional and therefore null and void it was repugnant to the constitution the philosophical argument that the constitution was a written document and the source of all american law supported this reasoning congress could not simply pass legislation ignoring the constitution's provisions as it had when it conferred to the court the ability to issue ritsumendamus via section 13 under its original jurisdiction [Music] although the opinion was clear that marbury had every right to receive both his commission and the office to which adams had appointed him this holding had the effect of rendering marbury's remedy impossible to issue marbury would never receive his commission but the effect of this case were far larger than his unfortunate outcome judicial review solidified the court's authority in a way that even the constitution itself had not expressly contemplated namely the doctrine made the court the final arbiter as to what was and was not constitutional now as we move forward in this series we will see how this doctrine is expanded and also how it underpinned some of the most momentous decisions in the court's history to be clear the concept did not completely emerge from a vacuum okay alexander hamilton seemed to have anticipated the doctrine in federalist 78 and 81 and some state courts had infrequently exercised similar powers despite state legislature objections nonetheless marbury v madison laid the foundation for the court's most powerful tool and secured its position as a truly co-equal branch of government able to nullify unconstitutional legislation and challenge unconstitutional actions historically the decision also skirted the shoals of political disaster quite well as we noted chief justice marshall was a federalist and jefferson a democrat republican moreover marshall was secretary of state when marbury's commission was created but not delivered there are all sorts of obvious conflicts of interest here regardless however in this opinion marshall was able to say that marbury and the federalists were within their rights but also satisfied jefferson and his party by rendering that fact nolan void now he did that by creating the doctrine of judicial review at the same time jefferson could not criticize the decision nor its novel doctrine too loudly now he couldn't do that because it had the effect of stymieing federalist control in the courts and granting the outcome that he no doubt wanted marshall recognized the opportunity that existed then and in taking it he crafted the most powerful tool in the court's toolbox judicial review now as we said from now on the court would be truly coequal to the congress and the presidency because it had the power at least in theory to check their legislation and actions [Music] all right if you made it this far thank you give the video a like leave a comment and subscribe to the channel be sure to check back often for more content have a nice day

Channel: Law & History

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Id: Yaeri3mD7EU

Length: 13min 14sec (794 seconds)

Published: Fri Apr 30 2021