In 1795, the Georgia legislature granted 35 million acres of land to private speculators at a very low price. When it was discovered that most of the legislators voting for the grant had been bribed, the legislature voided the grant the following year. Several years later, John Peck purchased some of the land in question, and subsequently sold it to Robert Fletcher. Fletcher subsequently sued Peck for breach of contract, alleging that the voiding of the initial grant had invalidated Peck's title to the land. The Supreme Court ruled that Georgia’s voiding of the 1795 grant was invalid because it violated a clause of the U.S. Constitution forbidding states to pass laws interfering with contracts. The decision in Fletcher v. Peck expanded the parameters of judicial review, as it marked the first time the Supreme Court struck down a state law as unconstitutional.

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