Facts of the Case
The Treaty of Paris, which ended the Revolutionary War, provided that creditors of both countries should “meet no lawful impediment” when recovering bona fide debts. A Virginia law passed during the American Revolution provided for the confiscation of such debts on the grounds that the debt was owed to an alien enemy. A resident of Virginia owed a debt to a British subject, and the British administrator sued in federal court to recover on the bond. The administrator argued that the Treaty of Paris ensured the collection of such debts.
Questions
Does the Treaty of Paris override an otherwise valid state law?
Conclusions
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Four of the five justices wrote opinions. Collectively, the justices held that federal courts had the power to determine the constitutionality of state laws. The Court invalidated the Virginia law under the Supremacy Clause, holding that federal treaties always take precedent over conflicting state laws.