Fletcher v. Peck
Following is the case brief for Fletcher v. Peck, 10 U.S. (6 Cranch) 87 (1810)
Case Summary of Fletcher v. Peck:
- The Georgia state legislature conveyed land to four companies in 1795.
- A year later, a newly elected legislature declared that the land conveyance was invalid.
- Peck, who acquired part of the conveyed land before the conveyance was declared invalid, later sold the land to Fletcher.
- Fletcher sued Peck for breach of contract, alleging that Peck had no legal right to sell the land, because the initial conveyance was deemed invalid.
- The U.S. Supreme Court determined, under the Contracts Clause of the Constitution, that Georgia did not have the power to invalidate the land conveyance. The Court, therefore, struck down the law making the conveyance invalid.
Fletcher v. Peck Case Brief
Statement of the Facts:
The State of Georgia, through its Legislature, conveyed land to four companies in 1795. It was later discovered that many of the legislators received bribes for agreeing to that conveyance. Because the corruption was made public, many of the bribed legislators were voted out of office. The following year, a new Legislature passed a bill stating that the 1795 conveyance of land was null and void.
Peck acquired part of the conveyed land before the new Legislature voided the initial conveyance. He then sold the land to Fletcher. When Fletcher learned that the initial conveyance of land was voided by state law, he sued Peck for breach of contract. He alleged that Peck had no legal right to sell the land, and that Peck had lied to him by claiming that he (Peck) had good title to the land.
Procedural History:
- The Circuit Court for the District of Massachusetts dismissed Fletcher’s lawsuit.
- The U.S. Supreme Court heard the case on Writ of Error.
Issue and Holding:
Can a State constitutionally repeal its sale of land consistent with the Contract Clause of the U.S. Constitution? No.
Judgment:
The decision of the Circuit Court for the District of Massachusetts is affirmed.
Rule of Law or Legal Principle Applied:
Once a State has made a sale of land, it cannot constitutionally repeal that sale without violating the Contracts Clause of the U.S. Constitution.
Reasoning:
The State of Georgia violated the Contracts Clause of the Constitution when it passed a law that repealed the land conveyance. Even though the land conveyance was the result of fraud and corruption, which the Court acknowledged was “deplorable,” it does not mean that the State can unwind a land deal upon which others relied.
Indeed, Peck purchased the land in question under the assumption that the conveyance was valid. Therefore, as an innocent third party, he fell outside the fraud of the initial conveyance and should not be disadvantaged by it. In addition, once the State of Georgia made a contract and completed performance on it, it cannot render the deal void at a later time. Accordingly, the law that repealed the initial conveyance must be struck down as unconstitutional.
Concurring and Dissenting Opinions:
Concurring in the Judgment (Johnson):
There is no question that a State does not have the power to repeal its own land grant, and there is no need to rely on the Constitution of the United States for that proposition. A State’s interest in land is not necessary to its political existence. A State selling land is the same as a person selling land. Once the sale is complete, the State has lost all control over it.
Significance:
Fletcher v. Peck is a landmark decision because it is the first time that the U.S. Supreme Court struck down a State law on constitutional grounds.
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