Everything about Dartmouth College V Woodward totally explained
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.
Background
The landmark case
Dartmouth v. William H. Woodward isn't without precedent. Earlier in the first instance of the Court invalidating a state legislative act the
Supreme Court had ruled in
Fletcher v. Peck,, that contracts, no matter how they were procured (in the case of
Fletcher, a land contract had been illegally obtained), can't be invalidated by state legislation. Thus, the court, though working in an early era, was treading on familiar ground when it handed down
Dartmouth.
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.
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.
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 wasn't 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's 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's viewed as a problematic extension of individual contract rights to artificial corporate entities.
Further Information
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