"Marbury v. Madison" (1803) is one of the most significant decisions in American legal history, as it established the principle of judicial review in U.S. law. This case formed the basis for the exercise of judicial power under the Constitution, allowing the Supreme Court to invalidate legislation or executive actions deemed inconsistent with the Constitution.
Background:
- Political Context: The case arose in the context of a bitter political rivalry between the Federalists and the Democratic-Republicans. In the 1800 election, Thomas Jefferson (a Democratic-Republican) defeated John Adams (a Federalist) for the presidency.
- Midnight Appointments: In the last days of his presidency, Adams sought to appoint several Federalists to new judicial positions created by the Judiciary Act of 1801. These last-minute appointments were known as the "Midnight Judges."
- William Marbury's Commission: William Marbury was one of the appointees, designated as a justice of the peace in the District of Columbia. Although his commission was signed and sealed, it was not delivered before Adams left office.
- Jefferson's Refusal: When Jefferson assumed the presidency, he ordered his Secretary of State, James Madison, not to deliver the commissions.
The Case:
- Marbury's Demand: Marbury petitioned the Supreme Court for a writ of mandamus, an order to compel Madison to deliver his commission.
- Legal Questions: The case raised two critical legal questions:
1. Did Marbury have a right to his commission?
2. If he had this right, and it was violated, did the law provide him a remedy?
The Decision:
- Chief Justice John Marshall: The opinion of the Court was written by Chief Justice John Marshall, a Federalist, who sought to avoid direct conflict with the Jefferson administration while establishing an important role for the Supreme Court.
- Marbury's Right to Commission: The Court held that Marbury had a right to his commission.
- Remedy through Judiciary: It also held that when a right is violated, the law generally provides a remedy.
Establishing Judicial Review:
- Judiciary Act of 1789: The critical turn in the case came when the Court examined the Judiciary Act of 1789, which had granted the Court the power to issue writs of mandamus in cases like Marbury's.
- Constitutional Conflict: The Court found that this provision of the Judiciary Act conflicted with Article III of the Constitution, which delineates the judicial power of the United States.
- Power to Invalidate Legislation: Marshall's opinion asserted that it was the duty of the judicial branch to determine what the law is and that if a law is found to be in conflict with the Constitution, then the law is invalid. This was the first time the Supreme Court declared an act of Congress unconstitutional, establishing the doctrine of judicial review.
Legacy:
"Marbury v. Madison" solidified the role of the Supreme Court as a co-equal branch of government, able to exert checks and balances on the other branches by reviewing the constitutionality of legislative and executive acts. This decision laid the foundation for the Court's central role in American law and politics, a role it continues to play to this day.
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