Marbury v Madison Case Brief
Facts
William Marbury,
the petitioner, was a Justice of the Peace in the District of Columbia. He was
appointed by then President John Adams around the end of the latter’s term. However,
when the new administration came into place, he was not granted his commission.
Because of this, he brought his petition to the Supreme Court to force one
Secretary of State, James Madison, to produce the documents that he required. He
sued for a writ of Mandamus.
Marbury was of
the opinion that the Supreme Court indeed had jurisdiction on the said issue.
He claimed that Secretary Madison had violated federal as well as
constitutional rules by not rewarding him with the commission he was entitled
to, and he also claimed that a writ of Mandamus was the right legal remedy for
his concern.
Procedural History
This case was
brought directly to the Supreme Court. The United States Supreme Court decided
on this case.
Issues
1. Was the act
of denying Marbury of his commission by the new administration violative of any
laws or statutes?
2. Was a writ of Mandamus the proper action to
take for Marbury?
Rule/s
On the first
question regarding the presence of a violation of the rights of Marbury, the
Court simply established whether or not he had indeed been properly appointed
by the former President. This would determine whether or not he had a vested
right that had been violated.
On the second
question regarding the propriety of the filing of a writ of Mandamus, the court
established the elements required before such could be granted and then
compared such to the case of Marbury. It also borough up the issue of the
Court’s jurisdiction.
Application
The issue of
whether or not Marbury had a right to demand the delivery of the commission in
question was determined by the Court by first determining the validity of his
appointment to the office. The Court examined the pertinent articles of the
Constitution in relation to Marbury’s appointment to his office and found that
his appointment lied in the sole discretion of the president. Since Marbury’s
commission was signed by the president and subsequently sealed by the secretary
of state, it is well-established that he was indeed entitled to the commission
under question.
The Court then
defined a writ of Mandamus and likewise enumerated some of its essential
requirements. Simply put, the Court defined a writ of Mandamus as a command
which is issued by the highest authorities when a person is deprived of his lawful
rights and or possessions and he has no other legal means to prevent such from
occurring. Such a writ is an order to a third party to do something which
pertains to his office and assigned duty which was previously conferred upon
him by the same authority. It may also be an order which, although not
pertaining to the specific duties of an individual, is for the furtherance of
justice and equity. In simpler terms, such a writ must be directed to a person
in authority, and the aggrieved party must not have any other legal remedy
available to him.
Using the
abovementioned criteria, the Court decided that indeed, Marbury was entitled to
demand that a writ of Mandamus be issued.
However, on the
question of jurisdiction, the Court was in conflict. A legislative act, the
Judiciary Act of 1789 gave it jurisdiction to grant Mandamus; on the other
hand, the Constitution did not.
Conclusion
It was
established in this case that the Supreme Court did not have proper
jurisdiction to issue a writ of Mandamus. Corollarily, it likewise declared the
Judiciary Act of 1789 unconstitutional.
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