Overview
This lecture covers the background, arguments, and significance of the 1819 Supreme Court case McCulloch v. Maryland, which clarified the relationship between federal and state powers and established key constitutional principles.
Background to the Case
- Debate over federal power began after the U.S. Constitution was ratified, focusing on whether Congress could charter a National Bank.
- Alexander Hamilton argued for a national bank as an implied power under the Necessary and Proper Clause.
- Thomas Jefferson and James Madison opposed, claiming the Constitution did not grant this express power.
- The First Bank of the United States was chartered in 1791 amid controversy and lapsed in 1811.
- The War of 1812 revealed the need for economic independence, leading to the Second Bank's charter in 1816.
- State banks, especially in Maryland, resented competition from the National Bank.
Maryland's Actions and Lawsuit
- In 1818, Maryland taxed the Baltimore branch of the Second Bank heavily to push it out of existence.
- James McCulloch, the branch's head cashier, refused to pay the tax, leading Maryland to sue him.
- The case began in Maryland courts and was eventually appealed to the U.S. Supreme Court.
Legal Arguments
- Maryland argued that the Constitution did not give Congress the express power to create a national bank, relying on the compact theory and states' rights (Virginia and Kentucky Resolutions).
- McCulloch, defended by Daniel Webster, argued that state actions could not impede legitimate federal operations.
The Supreme Court's Decision
- Chief Justice John Marshall's Court addressed two main questions: Is the Second Bank constitutional? Can a state tax it?
- The Court ruled the bank was constitutional, citing precedent, the sovereignty of the people, and the Necessary and Proper Clause (allowing implied powers).
- The Court rejected the compact theory, holding that the people created the Constitution, not the states.
- The Court ruled states cannot tax or obstruct constitutional federal actions, referencing the Supremacy Clause.
Significance and Impact
- The decision affirmed the federal government’s implied powers.
- It established federal supremacy over the states in constitutional matters.
- The ruling helped stabilize and strengthen the growing nation in the Era of Good Feelings.
Key Terms & Definitions
- Implied Powers — Powers not explicitly stated in the Constitution but considered necessary to execute expressed powers.
- Necessary and Proper Clause — Constitutional provision allowing Congress to pass laws needed to carry out its expressed powers.
- Supremacy Clause — Article VI, Clause 2 of the Constitution, declaring federal laws supreme over state laws.
- Compact Theory — The idea that states created the Constitution and can judge federal actions.
- McCulloch v. Maryland (1819) — Supreme Court case establishing federal implied powers and supremacy over states.
Action Items / Next Steps
- Review the text of the Necessary and Proper Clause and Supremacy Clause.
- Be able to summarize the significance of McCulloch v. Maryland for exam questions.