Editing Dartmouth College v. Woodward

{{Use mdy dates|date=September 2023}}
{{Infobox SCOTUS case
| Litigants = Trustees of Dartmouth College v. Woodward
| ArgueDate = 
| ArgueYear = 1818
| DecideDate = February 25
| DecideYear = 1819
| FullName = Trustees of Dartmouth College v. Woodward
| USVol = 17
| USPage = 518
| ParallelCitations = 4 [[Henry Wheaton|Wheat.]] 518; 4 [[L. Ed.]] 629
| Docket = 
| OralArgument = 
| OralReargument = 
| OpinionAnnouncement = 
| Prior = Error to the [[New Hampshire Superior Court]]
| Subsequent = 
| 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.
| Majority = Marshall
| JoinMajority = Johnson, Livingston
| Concurrence = Washington
| JoinConcurrence = Livingston
| Concurrence2 = Story
| JoinConcurrence2 = Livingston
| Concurrence/Dissent = 
| JoinConcurrence/Dissent = 
| Dissent = Duvall
| JoinDissent = 
| Dissent2 = 
| JoinDissent2 = 
| NotParticipating = Todd
| LawsApplied = [[Article One of the United States Constitution#Section 10: Limits on the States|U.S. Const. Art. 1, Sec. 10]]
}}

'''''Trustees of Dartmouth College v. Woodward''''', 17 U.S. (4 Wheat.) 518 (1819), was a [[List of landmark court decisions in the United States|landmark decision]] in [[United States corporate law]] from the [[Supreme Court of the United States|United States Supreme Court]] dealing with the application of the [[Contracts Clause]] of the [[United States Constitution]] to [[private corporation]]s. The case arose when the president of [[Dartmouth College]] was deposed by its [[Board of Trustees of Dartmouth College|trustees]], leading to the [[New Hampshire General Court|New Hampshire legislature]] attempting to force the college to become a public institution and thereby place the ability to appoint trustees in the hands of the [[governor of New Hampshire]]. The Supreme Court upheld the sanctity of the original charter of the college, which predated the creation of the State.<ref>{{ussc|name=Dartmouth College v. Woodward|volume=17|page=518|year=1819|reporter=Wheat.|reporter-volume=4}}.</ref>

The decision settled the nature of public versus private charters and resulted in the rise of the American business corporation and the American [[free enterprise system]].<ref>{{Cite book |last=Newmyer |first=R. K. |title=John Marshall and the heroic age of the Supreme Court |publisher=[[Louisiana State University Press]] |location=Baton Rouge |year=2001 |isbn=0-8071-2701-9 }}</ref>

==Background==
In 1769, [[King George III]] of [[Great Britain]] granted a charter to Dartmouth College that spelled out the purpose of the school, set up the structure to govern it, and gave it land. In 1816, over 30 years after the conclusion of the [[American Revolution]], the [[New Hampshire]] legislature altered Dartmouth's charter in order to reinstate the College's deposed president, place the ability to appoint positions in the hands of the governor, add new members to the board of trustees, and create a state-controlled board of visitors with veto power over trustee decisions. This effectively [[Nationalization|converted the school]] from a [[private school|private]] to a [[Public university|public institution]]. The College's book of records, corporate seal, and other corporate property were removed. The [[Board of Trustees of Dartmouth College|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 lawyer who later became a [[U.S. Senator]] for [[Massachusetts]] and [[United States Secretary of State|Secretary of State]] under [[President of the United States|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 called "a small college," adding, "and yet there are those who love it") was reportedly so moving that it helped convince [[John Marshall|Chief Justice John Marshall]] and almost brought Marshall to tears, according to the later recollection of attendant [[Chauncey A. Goodrich]].<ref>{{Cite web |last=WILSON |first=CARROLL A. |title=Daniel Webster and Dartmouth {{!}} Dartmouth Alumni Magazine {{!}} April 1943 |url=https://archive.dartmouthalumnimagazine.com/article/1943/4/1/daniel-webster-and-dartmouth |access-date=2025-01-14 |website=Dartmouth Alumni Magazine {{!}} The Complete Archive |language=en-US}}</ref>

==Judgment==
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 continue as a private institution and take back its buildings, seal, and charter. The majority opinion of the court was written by Marshall. The opinion reaffirmed Marshall's belief in the sanctity of a contract (also seen in ''[[Fletcher v. Peck]]''<ref name=Fletcher/>) as necessary to the functioning of a republic (in the absence of royal rule, contracts rule).{{according to whom|date=January 2017}}

The Court ruled that the college's corporate charter qualified as a contract between private parties, the King and the trustees, with which the legislature could not interfere. Even though the United States were no longer [[Crown colony|royal colonies]], the contract was still valid because the Constitution said that a state could not pass laws to impair a contract. The fact that the government had commissioned the charter did not transform the school into a civil institution. Marshall's opinion emphasized that the term "contract" referred to transactions involving individual property rights, not to "the political relations between the government and its citizens."<ref>The Oyez Project, [https://www.oyez.org/cases/1789-1850/17us518/ "Dartmouth College v. Woodward"], 17 U.S. 518 (1819)]</ref>

==Significance==
The decision was not without precedent; the Court had invalidated a state act in ''[[Fletcher v. Peck]]'' (1810),<ref name=Fletcher>{{ussc|name=Fletcher v. Peck|volume=10|page=87|pin=|year=1810|reporter=Cranch|reporter-volume=6}}.</ref> concluding that contracts, no matter how they were procured (in that case, a land contract had been illegally obtained), cannot be invalidated by state legislation. ''Fletcher'' was not a popular decision at the time, and a public outcry ensued. [[Thomas Jefferson]]'s earlier commiseration with New Hampshire Governor [[William 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]]. The courts, however, have imposed limitations on this.

After the Dartmouth decision, many states wanted more control, so they passed laws or constitutional amendments giving themselves the general right to alter or revoke at will, which the courts found to be a valid reservation.<ref>{{ussc|name=Miller v. State|link=|volume=82|page=478|pin=|year=1872|reporter=Wall.|reporter-volume=15}}.</ref><ref>{{ussc|name=Pennsylvania College Cases|link=|volume=80|page=190|pin=|year=1871|reporter=Wall.|reporter-volume=13}}.</ref> But the courts had established that the alteration or revocation of private charters or laws authorizing private charters must be reasonable and cannot cause harm to the members (founders, stockholders, and the like).<ref>{{ussc|name=Terrett v. Taylor|volume=13|page=43|pin=|year=1815|reporter=Cranch|reporter-volume=9}}.</ref><ref>{{ussc|name=Shields v. Ohio|volume=95|page=319|pin=|year=1877|reporter=|reporter-volume=}}.</ref><ref>{{ussc|name=Greenwood v. Freight Company|link=|volume=105|page=13|pin=|year=1881|reporter=|reporter-volume=}}.</ref>

The traditional view is that this case is one of the most important Supreme Court rulings, strengthening the [[Contracts Clause]] and limiting the power of the States to interfere with private charters, including those of commercial enterprises.<ref>{{Citation |title=Chapter 14. Private Contracts, the Contract Clause and the Police Power |date=1951-12-31 |url=http://dx.doi.org/10.7312/hend90602-015 |work=Charles Evans Hughes and the Supreme Court |pages=168–184 |access-date=2023-07-06 |publisher=Columbia University Press |doi=10.7312/hend90602-015 |isbn=978-0-231-87956-9 }}</ref>

== See also ==
* [[United States corporate law]]
* [[Dartmouth College]]
* [[John Marshall]]
* [[Contract Clause]]
* [[Special district (United States)]]
* ''[[Pennsylvania College Cases]]'' 80 U.S. 190 (1871)
* ''[[Case of Sutton's Hospital]]'' (1612) 77 Eng Rep 960
*''[[Phillips v Bury]]'', 1 Ld Raym 5; 2 TR 346, [[Lord Holt]]
*''[[Attorney-General v Pearce]]'', 2 Atk 87, [[Lord Hardwicke]]
*[[John Wheelock]]

== Notes ==
{{reflist}}

== External links ==
* {{wikisource-inline|Trustees of Dartmouth College v. Woodward|''Trustees of Dartmouth College v. Woodward''}}
* {{caselaw source
 | case=''Dartmouth College v. Woodward,'' {{ussc|17|518|1819|Wheat.|4|el=no}}
 | courtlistener =https://www.courtlistener.com/opinion/85282/dartmouth-college-v-woodward/
 | findlaw=https://caselaw.findlaw.com/us-supreme-court/17/518.html
 | justia=https://supreme.justia.com/cases/federal/us/17/518/
 | loc =http://cdn.loc.gov/service/ll/usrep/usrep017/usrep017518/usrep017518.pdf
 | openjurist =https://openjurist.org/17/us/518
 | oyez =https://www.oyez.org/cases/1818/0
}}

{{USArticleI}}
{{Dartmouth College}}

{{DEFAULTSORT:Dartmouth College V. Woodward}}
[[Category:Dartmouth College history|v. Woodward]]
[[Category:United States Constitution Article One case law]]
[[Category:United States Supreme Court cases of the Marshall Court]]
[[Category:United States corporate case law]]
[[Category:1819 in United States case law]]
[[Category:Contract Clause case law]]
[[Category:Legal history of New Hampshire]]
[[Category:Corporate personhood]]
[[Category:United States Supreme Court cases]]
[[Category:United States higher education case law]]