Dartmouth College v. Woodward

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Trs. of Dartmouth Coll. v. Woodward
Supreme Court of the United States
Decided February 2, 1819
Full case name: Trustees of Dartmouth College v. Woodward Citations: 17 U.S. 518; 4 L. Ed. 629 Prior history: ERROR to the Superior Court of the State of New Hampshire
Holding
The charter granted by the British crown to the trustees of Dartmouth College, in New-Hampshire, in the year 1769, is a contract within the meaning of that clause of the constitution of the United States, (art. 1. s. 10.) which declares that no State shall make any law impairing the obligation of contracts. The charter was not dissolved by the revolution.
Court membership
Chief Justice: John Marshall Associate Justices: Bushrod Washington, William Johnson, Henry Brockholst Livingston, Thomas Todd, Gabriel Duvall, Joseph Story
Case opinions
Majority by: Marshall Concurrence by: Washington Concurrence by: Story Concurrence by: Johnson (for reasons stated by Marshall) Concurrence by: Livingston (for reasons stated by Marshall, Washington, Story) Dissent by: Duvall
Laws applied
U.S. Const. Art. 1, Sec. 10

Trustees of Dartmouth College v. Woodward, 17 U.S. (4 Wheat.) 518 (1819), was a landmark United States Supreme Court case dealing with the application of the Contract Clause of the United States Constitution to private corporations.

[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 or alter Dartmouth's charter in order to reinstate the College's deposed president, effectively converting the school from a private to a public institution. The trustees of the College objected and sought to have the 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 for Massachusetts and Secretary of State under President Millard Fillmore. Webster argued the college's case against William H. Woodward, the state-approved secretary of the new board of trustees. Webster's speech in support 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 Marshall's eyes and apparently helped convince Chief Justice John Marshall.

[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. The opinion reaffirmed Marshall's belief in the sanctity of a contract (also seen in Fletcher v. Peck).

Dartmouth was not a popular decision at the time, and a public outcry ensued. Thomas Jefferson's earlier commiseration with New Hampshire Governor Plumer stated essentially that the earth belongs to the living. Popular opinion influenced some state courts and legislatures to declare that state governments had an absolute right to amend or repeal a corporate charter. Today opinion on Dartmouth remains mixed; for some it is viewed positively as one of the most important Supreme Court rulings, strengthening the Contract Clause and limiting the power of the States to interfere with private charters, including those of commercial enterprises; for others, it is viewed as a problematic extension of individual contract rights to artificial corporate entities.

[edit] See also

• List of United States Supreme Court cases, volume 17
• Dartmouth College
• John Marshall
• Contract Clause