Case Brief: Marbury v. Madison
This case arises from the failure of Secretary of State Madison to deliver a commission to William Marbury which would have made him a justice of the peace. The commission was signed by President Adams and the new presidential administration of President Jefferson through Secretary of State Madison refused to deliver the commission. Madison could have delivered the commission, he did not before Adams’ term as president expired, and the Jefferson administration refused to implement the wishes of the Adams administration on the grounds that the commission was no longer valid with the termination of Adams’ presidency.
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As a result, Marbury filed with the United States Supreme Court a writ of mandamus seeking to force Secretary Madison to deliver the commission. The Supreme Court was therefore required to decide a number of unique issues.
Issues Presented and Holdings
The first issue presented was whether Marbury was entitled to the commission appointing him a justice of the peace. The Court held that he was, in fact, entitled to the commission. The second issue presented was whether Marbury was entitled to a legal compensation or remedy. The court stated that compensation or remedies were available when legal injuries were suffered. The third issue presented was whether the Supreme Court had the power to review Congressional laws in order to determine whether these laws were constitutional. The Court found that it was within its power to review Congressional acts in order to determine whether they complied with or violated the constitution. The fourth issue presented was whether Congress had the power to expand the Supreme Court’s original jurisdiction in a manner which was more expansive than the original jurisdiction already set forth in the third article of the constitution. The Court held that Congress did not have the power to expand the constitution through a legislative act. The final issue presented, dependent upon the fourth issue presented, was whether the Court had the power to issue a writ of mandamus based on the Congressional act. The court held that the Court did not have this power.
Decision, Rationale and Analysis
The Supreme Court, in this decision, effectively ruled that the judicial and legislative powers are defined and limited according to the specific language contained in the federal constitution. Specifically, the constitution set forth the limits of the Supreme Court’s original jurisdiction in Article III and Congress’s legislative power could not be invoked in order to expand or otherwise violate this constitutional language. This was an important decision because it clearly stated the power of the United States Supreme Court to review acts of the legislative branch and it also provided that Congress could not unilaterally change the language of the constitution. The Supreme Court would thereafter be the sole arbiter of the constitution and Congress would be compelled to ensure that its legislative proposals conformed with minimum constitutional standards. Because the Congressional legislation purporting to expand the Supreme Court’s original jurisdiction was void in the instant case, with respect to the power to issue a writ of mandamus, Marbury could not receive this writ because it was beyond the Supreme Court’s power.
Marbury v. Madison 5 U.S. 137, 1 Cranch 137, 2 L. Ed. 60 (1803).
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