Dartmouth College v. Woodward

Tue, 10 Mar 1818 13:00:00 +0000

Location

Dartmouth College

Dartmouth College Hanover NH 03755

Hanover, NH 03755

United States

43° 42' 12.7764" N, 72° 17' 12.3288" W

See map: Google Maps

Case Basics

Petitioner

Dartmouth College

Petitioner Type

Petitioner

Respondent

Woodward

Respondent Type

Respondent

Heard By

Marshall Court (1812-1823)

Decided By

Marshall Court (1812-1823)

Opinion

17 U.S. 518 (1819)

Argued

Tuesday, March 10, 1818

Decided

Tuesday, February 2, 1819

Facts of the Case

In 1816, the New Hampshire legislature attempted to change Dartmouth College-- a privately funded institution--into a state university. The legislature changed the school's corporate charter by transferring the control of trustee appointments to the governor. In an attempt to regain authority over the resources of Dartmouth College, the old trustees filed suit against William H. Woodward, who sided with the new appointees.

Question

Did the New Hampshire legislature unconstitutionally interfere with Dartmouth College's rights under the Contract Clause?

Conclusion

Decision: 5 votes for Dartmouth College, 1 vote(s) against
Legal provision: US Const. Art 1, Section 10

In a 6-to-1 decision, the Court held that the College's corporate charter qualified as a contract between private parties, with which the legislature could not interfere. The fact that the government had commissioned the charter did not transform the school into a civil institution. Chief Justice 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."

Cases - 1818 term

Dartmouth College v. Woodward

Location