In Martin v. Hunter's Lessee (1816), 14 U.S. 304, the United States Supreme Court had previously rendered a judgment based on a treaty in a land dispute case. Despite that ruling, the Virginia Court of Appeals, in the same litigation, refused "to obey the mandate of this court, requiring the judgment . . . to be carried into due execution." Id., 323. That state's highest court had held that the United States Supreme Court exercised no appellate authority over it under the federal constitution, and, therefore, the Supremacy Clause was inapplicable. Id., 323-24. The United States Supreme Court disagreed and reversed the state court decision once again. Id., 355. In reaching its decision, the Supreme Court observed that "state courts would incidentally take cognizance of cases arising under the constitution, laws, and treaties of the United States." Id., 342. Further, the Supreme Court noted that, with respect to state courts, "they are expressly bound to obedience by the letter of the constitution; and if they should unintentionally transcend their authority, or misconstrue the constitution," their decisions are subject to appellate review by the Supreme Court of the United States. Id., 344. The observations in that case are important for what they do not say. The Supreme Court avoided divesting state courts of any power to construe the federal constitution, laws, and treaties. That Court recognized that state courts would occasionally need to apply federal law and the strictures of the federal constitution. When state courts do so, however, the United States Supreme Court is vested by the Constitution with appellate jurisdiction. Id., 323-24.The Supreme Court upheld the constitutionality of 25 of the Judiciary Act of 1789 which gave the Supreme Court appellate jurisdiction over appeals from state court systems. The Supreme Court said: "The Constitution has presumed (whether rightly or wrongly we do not inquire) that state attachments, state prejudices, state jealousies, and state interests, might sometimes obstruct, or control, or be supposed to obstruct or control, the regular administration of Justice. No other reason than that which has been stated can be assigned, why some, at least, of those cases should not have been left to the cognizance of the state courts." The Supreme Court of the United States pointed out in Martin v. Hunter's Lessee, the "necessity of uniformity of decisions" stating that "Judges of equal learning and integrity . . . might differently interpret . . . the Constitution," and warned, "if there were no revising authority to control these jarring and discordant judgments, and harmonize them into uniformity, . . . the Constitution of the United States would be different in different States and might, perhaps, never have precisely the same construction, obligation, or efficacy, in any two States. The public mischiefs that would attend such a state of things would be truly deplorable . . ."