Marbury v. Madison

5 U.S. (1 Cranch) 137 (1803)

Quick Summary

William Marbury (plaintiff) sought to enforce his appointment as Justice of the Peace by President Adams against James Madison (defendant), Secretary of State, who withheld Marbury’s commission on orders from President Jefferson. The dispute raised questions about Marbury’s entitlement and legal remedies available for enforcing his right.

The Supreme Court, through Chief Justice Marshall’s opinion, established that Marbury was entitled to his commission but could not be granted relief by this court as it did not have original jurisdiction in this case. This decision founded the principle of judicial review.

Facts of the Case

At the conclusion of his presidency, John Adams (plaintiff) appointed several individuals to judiciary positions, including William Marbury (plaintiff) as a Justice of the Peace for the District of Columbia. Although Congress approved these appointments and Adams signed their commissions, not all were delivered before his term ended.

Thomas Jefferson (defendant), the subsequent president, directed James Madison (defendant), his Secretary of State, not to deliver these remaining commissions. Marbury, whose commission was undelivered, petitioned the Supreme Court for a writ of mandamus to compel Madison to complete the delivery and thus formalize his appointment.

The dispute centered on whether Marbury was entitled to his commission and whether the Supreme Court had the authority to issue a writ of mandanus under its original jurisdiction as granted by the Judiciary Act of 1789. The case was a profound constitutional question involving the separation of powers and the ability of the judiciary to review executive actions.

Procedural Posture and History

  1. William Marbury was appointed a Justice of the Peace by outgoing President John Adams.
  2. The commission was signed and sealed but not delivered before President Adams left office.
  3. President Thomas Jefferson instructed Secretary of State James Madison not to deliver Marbury’s commission.
  4. Marbury petitioned the Supreme Court for a writ of mandamus to compel delivery of his commission.

I.R.A.C. Format

Issue

Whether Marbury had a right to his commission and if so, whether he had a remedy under U.S. law. Additionally, whether the Supreme Court had the authority to issue a writ of mandamus to enforce that right.

Rule of Law

The interpretation of the Constitution and statutes to determine whether an individual has been denied a right and if there exists a legal remedy for that denial.

Reasoning and Analysis

The Court reasoned that once President Adams signed Marbury’s commission, it became a completed act, conferring on Marbury a vested right to the office which could not be revoked by the succeeding administration. The Court further determined that withholding the commission violated Marbury’s legal right. As for remedy, Chief Justice Marshall invoked the principle that for every violation of a vested legal right there must be a legal remedy.

However, he concluded that the Supreme Court did not have original jurisdiction to issue a writ of mandamus as provided by the Judiciary Act of 1789 because that part of the Act was in conflict with Article III of the Constitution and therefore invalid.

This landmark decision established the doctrine of judicial review, which allows the Supreme Court to invalidate laws and executive actions that conflict with the Constitution. The Court established its role as the arbiter of constitutional interpretation, ensuring that no branch of government exceeds its constitutionally mandated powers.

Conclusion

The Court concluded that while Marbury had a right to his commission, it could not issue a writ of mandamus because it lacked original jurisdiction in this matter. Therefore, Marbury was entitled to his commission but did not receive it through this action.

Key Takeaways

  1. The signing and sealing of a commission by the President confers a vested right to an appointee.
  2. The Supreme Court has the power to review and invalidate laws and actions by other branches if they conflict with the Constitution (judicial review).
  3. The Judiciary Act of 1789 was partially unconstitutional as it extended the Court’s original jurisdiction beyond what Article III of the Constitution permitted.

Relevant FAQs of this case

What constitutes a vested legal right and how is it protected under the law?

A vested legal right arises when a person acquires a definitive, unconditional interest under the law that cannot arbitrarily be taken away without due process. To protect such rights, the legal system provides remedies, such as injunctions or damages, to redress any infringement.

  • For example: If a person has been promised a pension that has matured, they have a vested right to receive those payments. The law protects this right, ensuring that the person can legally enforce the payment against the pension fund or employer.

How does judicial review establish checks and balances among government branches?

Judicial review empowers courts to scrutinize the constitutionality of legislative acts and executive decisions, ensuring that they don’t exceed their lawful authority. As a check, it maintains the equilibrium of power by invalidating actions that violate constitutional provisions.

  • For example: If Congress passes a law restricting speech in a way that contradicts First Amendment protections, the courts can declare that law unconstitutional, thereby upholding the balance of power and protecting citizens’ rights.

Under what circumstances can a law be declared unconstitutional?

A law can be declared unconstitutional if it violates principles enshrined in the Constitution or exceeds the powers granted by it. The judiciary interprets the Constitution and applies its tenets to determine whether legislation aligns with constitutional mandates.

  • For example: A state law mandating that only certain religious groups may hold public office would be unconstitutional, as it violates the Establishment Clause of the First Amendment, which prohibits governmental endorsement of religion.

References

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