Marbury v. Madison

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Following is the case brief for Marbury v. Madison, United States Supreme Court, (1803)

Case Summary of Marbury v. Madison

  • Madison failed to finalize the former president’s appointment of William Marbury as Justice of the Peace.
  • Marbury directly petitioned the Supreme Court for an equitable remedy in the form of a writ of mandamus.
  • The Supreme Court held that although Marbury was entitled to a remedy, Section 13 of the Judiciary Act of 1789 expanding the Supreme Court’s original jurisdiction was unconstitutional.
  • Prior to this case, no law had been rendered unconstitutional. The major significance of Marbury v. Madison is that it helped define the original jurisdiction of the United States Supreme Court.

Marbury v. Madison Case Brief

Statement of the Facts:

Towards the end of his presidency, John Adams appointed William Marbury as Justice of the Peace for the District of Columbia.  After assuming office, President Thomas Jefferson ordered James Madison not to finalize Marbury’s appointment.  Under Section 13 of the Judiciary Act of 1789, Marbury brought an action against Madison in the United States Supreme Court requesting the Court to issue a writ of mandamus to force delivery of the appointment.

Procedural History:

Marbury directly approached the Supreme Court to compel Madison, Jefferson’s Secretary of State, to deliver the commission to Marbury.

Issues and Holdings:

  1. Does Marbury hold a right to his judicial appointment?  Yes
  2. Is Marbury entitled to a remedy under U.S. law?  Yes
  3. Is Marbury entitled to a writ of mandamus under Section 13 of the Judiciary Act of 1789?  No

Judgment:

Chief Justice John Marshall denied issuing a writ of mandamus.

Rule of Law or Legal Principle Applied:

The United States Supreme Court has the authority to review both the legislative acts of congress and laws to determine if they comply with the Constitution. 

Reasoning:

  • Justice Marshall held that although Marbury was entitled to his commission, the United States Supreme Court could not hear the case because it lacked original jurisdiction.
  1. Marbury was lawfully appointed as Justice of the Peace through the president’s (Adams) signing of Marbury’s commission and Senate confirmation.
  1. Under federal law, Marbury is entitled to a remedy. Whether or not Marbury may receive a remedy is contingent upon whether the appointment made Marbury an agent of the president or assigned a duty by law. If appointed as a political agent of the president, Marbury is not entitled to a remedy. However, if Marbury was deprived of the ability to carry out a duty assigned to him by law, Marbury is entitled to a remedy. Here, Adams gave legal title to the office of Justice of the Peace to Marbury for the length of the appointment. Madison interfered with Marbury’s legal title when he refused to finalize Marbury’s appointment. As a result, Marbury is entitled to a remedy.
  1. Section 13 of the Judiciary Act of 1789 authorizing the United States Supreme Court jurisdiction to provide the remedy of a writ of mandamus is unconstitutional. The Judiciary Act of 1789 permits the Supreme Court to exercise original jurisdiction over causes of actions for writs of mandamus. The problem is the provision directly conflicts with the Constitution, specifically Article III. Article III serves as a limitation on the types of cases the Supreme Court has original jurisdiction over.  Cases not within the Supreme Court’s original jurisdiction may fall under the Court’s appellate jurisdiction. In short, Section 13 of The Act is unconstitutional since it attempts to expand the original jurisdiction of the Supreme Court.

Concurring/Dissenting Opinions:

Unanimous decision

Significance:

The holding of Marbury v. Madison established the United States Supreme Court’s power to determine whether a law passed by Congress was constitutional (Judicial Review). Prior to this case, it was clear that laws conflicting with the Constitution were invalid, but the branch of government who determined validity had not been established.

Student Resources:

http://www.pbs.org/wnet/supremecourt/democracy/landmark_marbury.html
https://www.law.cornell.edu/supremecourt/text/5/137