Fletcher v. Peck: Difference between revisions
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==Yazoo lands sales== |
==Yazoo lands sales== |
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Following the [[Treaty of Paris (1783)|Treaty of Paris]] ending the [[American Revolution]], [[Georgia (U.S.)|Georgia]] claimed possession of the [[Yazoo lands]], a {{convert|35|e6acre|km2|adj=on}} region of the [[Indian Reserve (1763)|Indian Reserve]] west of its own territory. This land later became the states of [[Alabama]] and [[Mississippi]]. In 1795, the Georgia legislature divided the area into four tracts. The state then sold the tracts to four separate land development companies for a modest total price of $500,000, i.e. about 1.4 cents per acre ($3.46/km<sup>2</sup>), a good deal even at 1790s prices. The Georgia legislature overwhelmingly approved this land grant, known as the Yazoo Land Act of 1795. However, it was revealed that the Yazoo Land Act had been approved in return for [[bribes]]; after the scandal was exposed, [[voters]] rejected most of the incumbents in the next [[election]], and the new legislature, reacting to the public outcry, not only repealed the law but publicly burned it. |
Following the [[Treaty of Paris (1783)|Treaty of Paris]] ending the [[American Revolution]], [[Georgia (U.S.)|Georgia]] claimed possession of the [[Yazoo lands]], a {{convert|35|e6acre|km2|adj=on}} region of the [[Indian Reserve (1763)|Indian Reserve]] west of its own territory. This land later became the states of [[Alabama]] and [[Mississippi]]. In 1795, the Georgia legislature divided the area into four tracts. The state then sold the tracts to four separate land development companies for a modest total price of $500,000, i.e. about 1.4 cents per acre ($3.46/km<sup>2</sup>), a good deal even at 1790s prices. The Georgia legislature overwhelmingly approved this land grant, known as the Yazoo Land Act of 1795. However, it was revealed that the Yazoo Land Act had been approved in return for [[bribes]]; after the scandal was exposed, [[voters]] rejected most of the incumbents in the next [[election]], and the new legislature, reacting to the public outcry, not only repealed the law but publicly burned it. Fletcher bought land from Peck while the 1795 act was still in force. Fletcher brought this suit against Peck in 1803, claiming that Peck did not have clear title to the land when he sold it. |
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==Court ruling== |
==Court ruling== |
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Revision as of 21:08, 2 July 2013
| Fletcher v. Peck | |
|---|---|
 | |
| Argued February 15, 1810 Decided March 16, 1810 | |
| Full case name | Robert Fletcher v. John Peck |
| Citations | 10 U.S. 87 (more) 10 U.S. (6 Cranch) 87; 3 L. Ed. 162;1810 U.S. LEXIS 322; |
| Case history | |
| Prior | Demurrer overruled, D. Mass |
| Subsequent | None |
| Holding | |
| The Contracts Clause of the U.S. Constitution prohibited Georgia from voiding contracts for the transfer of land, even though they were secured through illegal bribery. Circuit Court for the District of Massachusetts affirmed. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Marshall, joined by Washington, Livingston, Todd |
| Concur/dissent | Johnson |
| Laws applied | |
| U.S. Const. art. I, § 10, cl. 1 | |
Fletcher v. Peck, 10 U.S. 87 (1810), was a landmark United States Supreme Court decision. The first case in which the Supreme Court ruled a state law unconstitutional, the decision also helped create a growing precedent for the sanctity of legal contracts, and hinted that Native Americans did not hold title to their own lands (an idea fully realized in Johnson v. M'Intosh).
Yazoo lands sales
Following the Treaty of Paris ending the American Revolution, Georgia claimed possession of the Yazoo lands, a 35-million-acre (140,000 km2) region of the Indian Reserve west of its own territory. This land later became the states of Alabama and Mississippi. In 1795, the Georgia legislature divided the area into four tracts. The state then sold the tracts to four separate land development companies for a modest total price of $500,000, i.e. about 1.4 cents per acre ($3.46/km2), a good deal even at 1790s prices. The Georgia legislature overwhelmingly approved this land grant, known as the Yazoo Land Act of 1795. However, it was revealed that the Yazoo Land Act had been approved in return for bribes; after the scandal was exposed, voters rejected most of the incumbents in the next election, and the new legislature, reacting to the public outcry, not only repealed the law but publicly burned it. Fletcher bought land from Peck while the 1795 act was still in force. Fletcher brought this suit against Peck in 1803, claiming that Peck did not have clear title to the land when he sold it.
Court ruling
The resulting case reached the Supreme Court which in a six to one decision ruled that the state legislature's repeal of the law was void because it was unconstitutional. The opinion written by John Marshall held that the sale was a binding contract, which according to Article I, Section 10, Clause I (the Contract Clause) of the Constitution, cannot be invalidated even if illegally secured and as a result the ruling lends further protection to property rights against popular pressures and is the earliest case of the Court asserting its right to invalidate state laws which are in conflict with or are otherwise contrary to the Constitution. William H. Rehnquist, one of Marshall's successors as Chief Justice wrote that Fletcher v. Peck "represented an attempt by Chief Justice Marshall to extend the protection of the contract clause to infant business."[1]
See also
Further reading
- John Marshall: Definer Of A Nation by Jean Edward Smith, 1996, Henry Holt & Company.
- Yazoo: Law and Politics in the New Republic: The Case of Fletcher v. Peck by C. Peter Magrath, 1966 ISBN 0-608-18419-5
Footnotes
- ^ Rehnquist, William. A Random Thought on the Segregation Cases, Memo to Justice Robert H. Jackson
External links
- Text of Fletcher v. Peck, 10 U.S. 87 (1810) is available from: Findlaw Justia LII University of Tulsa
- The Oyez Project
- Famous Cases
- Case Brief for Fletcher v. Peck at Lawnix.com