Fletcher v. Peck

Case Date: 02/26/2021

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). 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. It was revealed that the Yazoo Land Act sale to private speculators had been approved in return for bribes and after the scandal was exposed, voters rejected most of the incumbents in the next election, and the next legislature, reacting to the public outcry, repealed the law and voided transactions made under it. John Peck had purchased land that had previously been sold under the 1795 act and later sold this land to Robert Fletcher who then brought this suit against Peck in 1803, claiming that he did not have clear title to the land when he sold it. Interestingly, this was a case of collusion. Both Fletcher and Peck were land speculators whose holdings would be secured if the Supreme Court decided that Indians did not hold original title--and so Fletcher set out to lose the case.[1] The resulting case reached the Supreme Court which in a unanimous 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."[2]