United States v. Peters (1795)

United States v. Peters was a landmark case decided by the Supreme Court of the United States, establishing the supremacy of federal courts in matters of admiralty and prize law over state courts. The case arose from a dispute over the proceeds of a captured British vessel, the Active, during the Revolutionary War.

Background:

The Active was captured in 1779 by a Pennsylvania privateer, and the proceeds from its sale were distributed, in part, to the crew. However, David Rittenhouse, then the Treasurer of Pennsylvania, claimed a share of the prize money on behalf of the state, arguing that the privateer had been commissioned by Pennsylvania. The Pennsylvania state courts upheld Rittenhouse's claim.

Federal Court Action:

The United States government, acting on behalf of the original crew members who had assigned their claims, filed suit in federal district court to recover the money held by Rittenhouse's heirs (he had since passed away). Judge Richard Peters, the district judge for Pennsylvania, ruled in favor of the United States, ordering the Rittenhouse heirs to pay the funds to the crew.

Pennsylvania's Resistance:

The state of Pennsylvania, believing its sovereignty was being violated, refused to comply with the federal court order. The Pennsylvania legislature passed a law directing the state marshal to use force to prevent the enforcement of the federal court's decree.

Supreme Court Decision:

The case eventually reached the Supreme Court, which, in 1809, reaffirmed Judge Peters's ruling in United States v. Peters. Chief Justice John Marshall, writing for the Court, held that the federal courts had exclusive jurisdiction over admiralty and prize cases. The Court rejected Pennsylvania's claim of state sovereignty, asserting that the federal government's authority was supreme in matters delegated to it by the Constitution. The Court emphasized that state laws could not interfere with the lawful judgments of federal courts.

Significance:

United States v. Peters is a significant case in American constitutional law because it firmly established the principle of federal judicial supremacy in matters within the federal courts' jurisdiction. It reinforced the idea that the federal government, within its enumerated powers, is supreme over the states. It also highlighted the potential for conflict between state and federal authority and the role of the Supreme Court in resolving such disputes. The case is an early example of the Court asserting its power to review and overturn state actions that conflicted with federal law. It is studied as a key example in the development of federalism and the relationship between state and federal courts in the United States.