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2 The Case 3 The Decision 4 References 5 See also |
The landmark case Dartmouth College v. Woodward is not without precedent. Earlier, the Marshall Court, in the first instance of the Court invalidating a state legislative act, had ruled in Fletcher v. Peck 10 US 87 1810 that contracts, no matter how they were procured (in the case of Fletcher, a land contract had been illegally obtained), must be honored. Thus, the court, though working in an early era, was treading on familiar ground when it handed down Dartmouth.
Dartmouth College’s charter was granted by King George III of the United Kingdom on 13 December 1769. 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 act of the legislature declared unconstitutional.
The trustees thus hired Daniel Webster, who represented New Hampshire in the U.S. Senate, later served as Secretary of State, and was the college's most famous alumnus up to that time, to defend the college in court. Webster's speech in defense of Dartmouth was so moving that it reportedly brought tears to Chief Justice Marshall's eyes.
The decision, handed down on 2 February 1819, ruled in favor of the college, and thus invalidated the act of the New Hampshire legislature; which, in turn, allowed Dartmouth to remain a private institution. The majority opinion was, predictably, written by Marshall.
Dartmouth at the time was not a popular decision. When the United States Supreme Court ruled for Dartmouth, a public outcry ensued. State courts and legislatures, supported by the people, declared that state governments had an absolute right to amend or repeal a corporate charter. [1]
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’ dominion.
Background
The Case
The Decision
References
See also