## Facts

- Eakin and the Simpsons brought an ejectment action to recover an undivided moiety of four town lots (Nos. 77–80) in Easton, Pennsylvania, claiming title through a will associated with Dr. Andrew Ledlie’s estate.
- The plaintiffs resided overseas (“beyond sea”) while the defendants possessed the lots.
- Defendants asserted a statute-of-limitations defense based on a Pennsylvania limitations act of March 11, 1815, which altered time limits previously governed by a 1785 limitations act that included a saving provision for persons beyond sea.
- The trial court instructed the jury in a manner that effectively treated the 1815 act as an immediate retrospective bar to the plaintiffs’ claim; the jury returned a verdict for defendants.
- Plaintiffs sought review by writ of error in the Supreme Court of Pennsylvania.

## Issues

1. Whether the 1815 limitations act barred, by retrospective operation, claims of persons beyond sea who had been out of possession for twenty-one years before the act’s enactment.
2. Whether, if a legislative act is a manifest breach of the Pennsylvania Constitution, a court has authority and duty to treat the act as void (discussed but not necessary to the judgment).
3. Whether the judiciary may invalidate state statutes under the state constitution absent express constitutional authorization (raised in dissent).

## Decision

- The Supreme Court of Pennsylvania reversed the judgment and ordered a new trial.
- The court held the 1815 act was not to be construed as an immediate retrospective bar against persons beyond sea who had been out of possession for twenty-one years before the act.
- Such claimants had fifteen years from March 11, 1815, to bring suit, consistent with the structure referenced from the 1785 limitations act.
- In dictum, the majority stated that courts have a right and duty to declare void a legislative act that is a manifest breach of the state constitution.
- Justice Gibson dissented on the judicial-review question, disputing an implied judicial power to annul state statutes under the state constitution.

## Legal Principles

- Limitations statutes that alter filing periods are generally construed prospectively absent clear legislative direction to impose an immediate retrospective bar, especially where an instantaneous bar would be inconsistent with principles of natural justice.
- When a statute is fairly susceptible to a constitutional and non-constitutional construction, a court may resolve the case on the narrower statutory ground and avoid reaching constitutional validity.
- (Dictum, majority) If a legislative enactment is a manifest breach of the state constitution, courts have both the authority and duty, in deciding cases, to give effect to the constitution over the conflicting statute.
- (Dissent) Absent express state-constitutional authorization (in terms or by necessary implication), state courts should not invalidate state statutes on state-constitutional grounds; political checks and repeal are the principal remedies, though courts must disregard state laws conflicting with federal law under the Supremacy Clause.

## Conclusion

The court held that the 1815 amendment to Pennsylvania’s statute of limitations did not immediately and retroactively bar land claims of persons beyond sea; instead, it allowed a fifteen-year window from the act’s effective date, and it reversed for a new trial, while separately dividing the court over the legitimacy of state judicial review in dictum and dissent.


Eakin v. Raub, 12 Serg. & Rawle 330 (Pa. 1825)