Cohens v. Virginia
Facts
Congress authorized a lottery for the District of Columbia as a means of raising revenue. Under this federal authorization, tickets for the lottery were sold in various locations, including the state of Virginia.
The Cohens brothers were convicted in Virginia state court for selling tickets for the D.C. lottery, in violation of Virginia law, which prohibited the sale of out-of-state lottery tickets. The Cohens argued that because Congress had authorized the lottery, their conduct was protected under federal law and therefore could not be punished by the state.
After being convicted and fined in state court, the Cohens sought review in the United States Supreme Court. Virginia opposed Supreme Court jurisdiction, arguing that the Court did not have authority to review criminal cases decided by state courts, particularly where the state itself was a party.
The central dispute thus became whether the Supreme Court had appellate jurisdiction over state court decisions involving questions of federal law, even in criminal cases.
Issues
Whether the United States Supreme Court has appellate jurisdiction to review state court criminal decisions that involve questions of federal law.
Rule
The United States Supreme Court has appellate jurisdiction to review state court decisions—both civil and criminal—when those decisions involve questions of federal law or the U.S. Constitution.
Application
The Court, led by Chief Justice John Marshall, emphasized the supremacy of federal law and the necessity of a uniform interpretation of the Constitution. Without Supreme Court oversight, state courts could interpret federal law inconsistently, undermining national uniformity.
The Court rejected Virginia’s argument that criminal cases should be treated differently from civil cases. The Constitution does not distinguish between types of cases when granting appellate jurisdiction; instead, it extends to all cases arising under federal law.
Marshall also addressed the concern that allowing Supreme Court review of state court decisions would infringe on state sovereignty. He clarified that while states retain significant authority, they are bound by the Constitution and federal laws, which are the supreme law of the land.
The Court further reasoned that the judiciary has a duty to say what the law is, and this responsibility necessarily includes reviewing lower court decisions that implicate federal issues. Denying jurisdiction in such cases would allow states to effectively nullify federal law by insulating their decisions from review.
Finally, the Court distinguished between suits against a state and appellate review of a state court judgment. Although states may have sovereign immunity from certain lawsuits, that immunity does not prevent the Supreme Court from reviewing a state court’s decision when federal law is at issue.
Holding
Yes. The Supreme Court has appellate jurisdiction to review state court criminal decisions that involve questions of federal law.
Court
This case was decided by the United States Supreme Court, which affirmed its authority to review state court judgments involving federal issues.
Exam Notes
- Confirms Supreme Court appellate review over state court decisions
- Applies to both civil and criminal cases
- Reinforces federal supremacy and need for uniform interpretation
- Important distinction: not a suit against the state, but review of a judgment
- Builds on Martin v. Hunter’s Lessee (civil context)
- Key principle: states cannot insulate federal questions from review
- Frequently tested in judicial review / federal courts topics
- Shows limits of state sovereignty when federal law is involved