Dispute-
Two brothers, P.J. and M.J. Cohen had been appointed by Congress to administer lottery tickets within the city of the District of Columbia to raise funds and improve city living conditions. They were, then justified by federal approval to sell lottery tickets throughout D.C., however, they chose to also sell tickets in the Commonwealth of Virginia. The issue arose because of a Virginia law passed and enacted as of the beginning of 1820, that any purchase of lottery tickets or existence of any sort of lottery was illegal by state law. Once state authorities were made aware of the selling of lottery tickets in their Commonwealth, they brought the Cohen brothers to the state court, convicted them, and sentenced a $100 fine. The Cohen brothers, however, noting the Supreme Court’s recent rulings in cases such as Fletcher v. Peck and Dartmouth College v. Woodward protecting the jurisdiction of the federal government over that of the states, chose to appeal to the Supreme Court.
Constitutional Principle Affirmed: The Supremacy Clause- "Constitution, and the Laws of the United States… shall be the Supreme Law of the Land." Article VI, Section 2. This principle essentially states all states laws' are secondary and cannot overrule federal law.
Significance-
The decision of the aforementioned case is not the critical portion of John’s Marshall’s ruling. The Supreme Court upheld the conviction made by the State of Virginia, and ordered the Cohen brothers pay the fine of $100 as if one was in the territory of a state he/she was subject to its laws. The controversy, instead laid in the State of Virginia’s proclaiming their courts to be the final arbiters of the case, and would rule any decision of the Supreme Court null and void. John Marshall explicitly explains in his decision that the Court had the jurisdiction to review all state criminal proceedings, if they so choose. Marshall explained that if any state laws were unconstitutional in the eyes of the Supreme Court, and countered federal law, they were “absolutely void.” Although he ultimately agreed with the Virginia Court’s decision, this case set the important precedent all state convictions were subject to federal review. This is of utmost importance in recognizing the expansion of federal power over the states, as Marshall’s nationalistic motives are revealed to assist growth of a strong, unified nation.
Two brothers, P.J. and M.J. Cohen had been appointed by Congress to administer lottery tickets within the city of the District of Columbia to raise funds and improve city living conditions. They were, then justified by federal approval to sell lottery tickets throughout D.C., however, they chose to also sell tickets in the Commonwealth of Virginia. The issue arose because of a Virginia law passed and enacted as of the beginning of 1820, that any purchase of lottery tickets or existence of any sort of lottery was illegal by state law. Once state authorities were made aware of the selling of lottery tickets in their Commonwealth, they brought the Cohen brothers to the state court, convicted them, and sentenced a $100 fine. The Cohen brothers, however, noting the Supreme Court’s recent rulings in cases such as Fletcher v. Peck and Dartmouth College v. Woodward protecting the jurisdiction of the federal government over that of the states, chose to appeal to the Supreme Court.
Constitutional Principle Affirmed: The Supremacy Clause- "Constitution, and the Laws of the United States… shall be the Supreme Law of the Land." Article VI, Section 2. This principle essentially states all states laws' are secondary and cannot overrule federal law.
Significance-
The decision of the aforementioned case is not the critical portion of John’s Marshall’s ruling. The Supreme Court upheld the conviction made by the State of Virginia, and ordered the Cohen brothers pay the fine of $100 as if one was in the territory of a state he/she was subject to its laws. The controversy, instead laid in the State of Virginia’s proclaiming their courts to be the final arbiters of the case, and would rule any decision of the Supreme Court null and void. John Marshall explicitly explains in his decision that the Court had the jurisdiction to review all state criminal proceedings, if they so choose. Marshall explained that if any state laws were unconstitutional in the eyes of the Supreme Court, and countered federal law, they were “absolutely void.” Although he ultimately agreed with the Virginia Court’s decision, this case set the important precedent all state convictions were subject to federal review. This is of utmost importance in recognizing the expansion of federal power over the states, as Marshall’s nationalistic motives are revealed to assist growth of a strong, unified nation.
