The Supreme Court's Power to Review State Courts- Martin v. Hunter's Lessee

In our previous case, Marbury v. Madison, we saw how the Supreme Court interpreted the Constitution to mean that any federal laws that were in conflict with provisions in the Constitution were invalid and had to be struck down.

Our next case shows the Supreme Court's authority over state court decisions. The case specifically involves another provision in the Judiciary Act of 1789. Section 25 of the Act provided for Supreme Court review of final decisions of the highest state courts that involved claims based on federal law (which also includes the Constitution).

While the Constitution was being developed and debated, the delegates were aware that sometimes federal questions could initially arise in state courts. For example, imagine a person charged with a crime makes five arguments to defend himself, including one argument that his acts were protected by the 1st Amendment (the rest were arguments recognized under state law). The case will likely be tried in state court because only one of the issues involves the constitution, while the other four arguments involved state law. 

Everyone assumed that if the state court made a decsion that touched upon a federal or constitutional law issue, the Supreme Court would be able to review it to ensure uniformity of federal law (the state supreme courts ensured uniformity of state law issues). But that assumption would be tested in the 1816 case Martin v. Hunter's Lessee.