Fletcher v. Peck

Fletcher v. Peck
Supreme Court of the United States
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;
Prior history	Demurrer overruled, D. Mass
Subsequent history	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
Chief Justice John Marshall Associate Justices William Cushing · Samuel Chase Bushrod Washington · William Johnson Henry B. Livingston
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), is 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voters rejected most of the incumbents in the next election, and the new legislature, reacting to the public outcry, repealed the law and voided transactions made under it.

Robert Fletcher, and especially John Peck, were speculators in the Yazoo lands. Fletcher bought a tract of land from Peck while the 1795 act was still in force. Fletcher later (1803) brought this suit against Peck, claiming that Peck had not had clear title to the land when he sold it. Interestingly, this was a case of collusion. Both Fletcher's and Peck's land holdings would be secured if the Supreme Court decided that Indians did not hold original title—and so Fletcher set out to win the case.

Court ruling

The resulting case reached the Supreme Court which in a unanimous decision (with a separate concurring opinion written by William Johnson) 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."

See also

• List of United States Supreme Court cases, volume 10
• Yazoo land scandal

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

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