Marbury v. Madison (1803)

Marbury v. Madison, Supreme Court, 1803

Facts of the Case

In the final days of his presidency, John Adams appointed several judges, including William Marbury, as justices of the peace in the District of Columbia. These appointments, known as the “midnight judges,” were part of the Judiciary Act of 1801. However, when Thomas Jefferson took office, his Secretary of State, James Madison, refused to deliver the commissions. Marbury petitioned the Supreme Court to compel Madison to deliver the commission, invoking the Court’s original jurisdiction under the Judiciary Act of 1789.

Constitutional Question

  1. Does Marbury have a right to his commission?
  2. If he has a right, and that right has been violated, do the laws of the country provide him a remedy?
  3. If they do provide him a remedy, is it a mandamus issuing from the Supreme Court?

Arguments

For Marbury:

  • Marbury’s appointment was valid once it was signed and sealed, and the delivery of the commission was a mere formality.
  • The refusal to deliver the commission violated Marbury’s legal rights, and he is entitled to a remedy.
  • The Supreme Court has the authority to issue a writ of mandamus compelling Madison to deliver the commission.

For Madison:

  • The appointments were political acts and not subject to judicial review.
  • The delivery of the commission was essential for the appointment to be completed.
  • The Supreme Court does not have the authority to issue a writ of mandamus in this case, as it falls outside its original jurisdiction.

The Decision

The Supreme Court, in a unanimous decision written by Chief Justice John Marshall, ruled that:

  1. Marbury had a right to his commission.
  2. Marbury’s right to his commission had been violated, and the law provided him a remedy.
  3. However, the Court did not have the authority to issue a writ of mandamus because the section of the Judiciary Act of 1789 that granted the Supreme Court the power to issue such writs in this case was unconstitutional.

Chief Justice Marshall concluded that the Judiciary Act of 1789 extended the Court’s original jurisdiction beyond what was defined in Article III of the Constitution. By declaring this part of the Judiciary Act unconstitutional, Marshall established the principle of judicial review, giving the Supreme Court the power to declare acts of Congress unconstitutional.

Significance

Marbury v. Madison is a landmark case that established the principle of judicial review, the power of the courts to examine and invalidate laws and executive actions that are contrary to the Constitution. This decision significantly strengthened the role of the judiciary in American government by positioning the Supreme Court as a co-equal branch with the authority to interpret the Constitution. The case has had a lasting impact on the balance of power among the branches of government and continues to serve as a foundational precedent in constitutional law.