Fletcher v Peck (1810)
Overview: In Fletcher vs. Peck, the Supreme Court ruled that a grant to a private land company was a contract within the meaning of the Contract Clause of the Constitution, and once made could not be repealed, regardless of the circumstances under which it was made.
Conflict: In 1795, the Georgia state legislature granted roughly 35 million acres of state land to the Yazoo Land Companies for the rate of 1.5 cents per acre. It was later discovered that the deal was shrouded by corruption, and all but one legislator had been bribed. In 1796, a new state legislature repealed the corrupt land grant. In 1800, John Peck bought some of the land that was part of the 1795 grant, and sold 13000 acres of it to Robert Fletcher in 1803. When Fletcher discovered that the sale of the land had been voided by state law, he sued Peck, hoping to get damages, on the grounds that Peck had lied to him as to the status of the land. A federal circuit court ruled in favor of Peck, but Fletcher appealed to the Supreme Court. The question left for the court to answer was whether or not the act of 1796 (repealing the act of 1795) was a violation of Article 1, Section 10 of the Constitution. In other words, once the state of Georgia approved the sale of the land, was it allowed under the Constitution to repeal that sale or not?
Decision/Impact: The court’s decision showed strict adherence to the phrasing on the Contract Clause of the Constitution (found in Article 1, Section 10) which forbids states from: “passing any Law impairing the obligation of contracts”. The court decided that the act of the Georgia legislature rescinding a land grant was unconstitutional because it revoked the rights previously granted by the contract. This decision was monumental in that it marked the first time that the Supreme Court had struck down a state law on Constitutional grounds. This was a landmark case in consolidating the power of the federal government over that of the states. It also proved the Marshall Court to be committed to promoting commerce, a position which it would maintain for the remainder of its existence.
Article 1, Section 10 of the United States Constitution
"SECTION 10.No state shall enter into any treaty, alliance, or confederation; grant letters of marque and reprisal; coin money; emit bills of credit; make anything but gold and silver coin a tender in payment of debts; pass any bill of attainder, ex post facto law, or law impairing the obligation of contracts, or grant any title of nobility.
No state shall, without the consent of the Congress, lay any imposts or duties on imports or exports, except what may be absolutely necessary for executing it's inspection laws: and the net produce of all duties and imposts, laid by any state on imports or exports, shall be for the use of the treasury of the United States; and all such laws shall be subject to the revision and control of the Congress.
No state shall, without the consent of Congress, lay any duty of tonnage, keep troops, or ships of war in time of peace, enter into any agreement or compact with another state, or with a foreign power, or engage in war, unless actually invaded, or in such imminent danger as will not admit of delay."
Justice John Marshall's decision
Overview: In Fletcher vs. Peck, the Supreme Court ruled that a grant to a private land company was a contract within the meaning of the Contract Clause of the Constitution, and once made could not be repealed, regardless of the circumstances under which it was made.
Conflict: In 1795, the Georgia state legislature granted roughly 35 million acres of state land to the Yazoo Land Companies for the rate of 1.5 cents per acre. It was later discovered that the deal was shrouded by corruption, and all but one legislator had been bribed. In 1796, a new state legislature repealed the corrupt land grant. In 1800, John Peck bought some of the land that was part of the 1795 grant, and sold 13000 acres of it to Robert Fletcher in 1803. When Fletcher discovered that the sale of the land had been voided by state law, he sued Peck, hoping to get damages, on the grounds that Peck had lied to him as to the status of the land. A federal circuit court ruled in favor of Peck, but Fletcher appealed to the Supreme Court. The question left for the court to answer was whether or not the act of 1796 (repealing the act of 1795) was a violation of Article 1, Section 10 of the Constitution. In other words, once the state of Georgia approved the sale of the land, was it allowed under the Constitution to repeal that sale or not?
Decision/Impact: The court’s decision showed strict adherence to the phrasing on the Contract Clause of the Constitution (found in Article 1, Section 10) which forbids states from: “passing any Law impairing the obligation of contracts”. The court decided that the act of the Georgia legislature rescinding a land grant was unconstitutional because it revoked the rights previously granted by the contract. This decision was monumental in that it marked the first time that the Supreme Court had struck down a state law on Constitutional grounds. This was a landmark case in consolidating the power of the federal government over that of the states. It also proved the Marshall Court to be committed to promoting commerce, a position which it would maintain for the remainder of its existence.
Article 1, Section 10 of the United States Constitution
"SECTION 10.No state shall enter into any treaty, alliance, or confederation; grant letters of marque and reprisal; coin money; emit bills of credit; make anything but gold and silver coin a tender in payment of debts; pass any bill of attainder, ex post facto law, or law impairing the obligation of contracts, or grant any title of nobility.
No state shall, without the consent of the Congress, lay any imposts or duties on imports or exports, except what may be absolutely necessary for executing it's inspection laws: and the net produce of all duties and imposts, laid by any state on imports or exports, shall be for the use of the treasury of the United States; and all such laws shall be subject to the revision and control of the Congress.
No state shall, without the consent of Congress, lay any duty of tonnage, keep troops, or ships of war in time of peace, enter into any agreement or compact with another state, or with a foreign power, or engage in war, unless actually invaded, or in such imminent danger as will not admit of delay."
Justice John Marshall's decision
