Marbury v. Madison – Key Points

Election and Judiciary Act

• Thomas Jefferson defeated John Adams in the $1800$ presidential election.
• Before leaving office (March $1801$), Adams and the Federalist Congress passed the Judiciary Act of $1801$:
  • Created new federal courts.
  • Added $16$ circuit judges and $42$ justices of the peace.
  • Expanded presidential appointment power.

Marbury's Appointment and Issue

• William Marbury named Justice of the Peace for the District of Columbia.
• Commission signed and sealed but not delivered; new Secretary of State James Madison refused delivery.

Supreme Court Proceedings

• Marbury (with $3$ others) petitioned the Supreme Court for a writ of mandamus compelling delivery.
• Petition relied on Section $13$ of the Judiciary Act of $1789$, granting the Court original jurisdiction to issue such writs.

Court's Decision (Marshall, $1803$)

• Madison’s refusal was illegal.
• Writ of mandamus would be an appropriate remedy.
• Section $13$ of the Judiciary Act of $1789$ unconstitutionally expanded the Court’s original jurisdiction beyond Article $III$, Section $2$.
• Consequently, the Court lacked authority to issue the writ.

Principle Established

• Judicial Review: Supreme Court can declare congressional statutes unconstitutional.
• Justification: Supremacy Clause makes the Constitution superior to ordinary legislation; Congress cannot alter it through regular laws.