Dartmouth College v. Woodward

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Trustees of Dartmouth College vs. Woodward, 17 U.S. 518 (1819)^[1], was an important United States Supreme Court case dealing with the application of the Contract Clause of the United States Constitution to private corporations.

1 Background
2 Case
3 Decision
4 References
5 See also
6 External links

[edit] Background

The landmark case Dartmouth v. William H. Woodward is not without precedent. Earlier in the first instance of the Court invalidating a state legislative act the Supreme Court had ruled in Fletcher v. Peck, 10 U.S. 87 (1810) that contracts, no matter how they were procured (in the case of Fletcher, a land contract had been illegally obtained), cannot be invalidated by state legislation. Thus, the court, though working in an early era, was treading on familiar ground when it handed down Dartmouth.

[edit] Case

In 1815, over thirty years after the conclusion of the American Revolution, the legislature of New Hampshire attempted to invalidate Dartmouth's charter in order to convert the school from a private to a public institution. The trustees of the College objected, and thus sought to have the attempted actions of the legislature declared unconstitutional.

Painting by Robert Clayton Burns (1962) depicting Daniel Webster and the Dartmouth College Case

The trustees retained Dartmouth alumnus Daniel Webster, a New Hampshire native who would later become a U.S. Senator from Massachusetts and Secretary of State under President Millard Fillmore. Webster was hired to argue the college's case in court against William H. Woodward, the state-appointed secretary of the new board of trustees. Webster's speech in defense of Dartmouth (which he described as "a small college," adding, "and yet there are those who love it") was so moving that it reportedly brought tears to Chief Justice Marshall's eyes.

[edit] Decision

The decision, handed down on February 2, 1819, ruled in favor of the College and invalidated the act of the New Hampshire legislature; which, in turn, allowed Dartmouth to exist as a private institution and take back its buildings, seal, and charter. The majority opinion was, predictably, written by Marshall. This again affirmed Marshall's belief in the sanctity of a contract (also seen in Fletcher v. Peck; 1810).

Dartmouth at the time was not a popular decision. When the United States Supreme Court ruled for Dartmouth, a public outcry ensued. Jefferson commiserated with New Hampshire Governor Plumer, writing in essence that the earth belongs to the living. State courts and legislatures, supported by the people, declared that state governments had an absolute right to amend or repeal a corporate charter.

However, today Dartmouth is considered to be one of the most important Supreme Court rulings, strengthening the Contract Clause and limiting the power of the States to interfere with private institutions' charters. The decision protected contracts against specifically state encroachments. More recently it has had the effect of safeguarding business enterprises from state governments’ domination.