Trustees of Dartmouth College v. Woodward

Following is the case brief for Trustees of Dartmouth College v. Woodward, 17 U.S. 518 (1819)

Case Summary of Trustees of Dartmouth v. Woodward:

  • Dartmouth College received its charter from the British Crown before the American Revolution.  After the Revolution, the State of New Hampshire altered the charter to take control over the college.
  • The Trustees sued to maintain private control of the college.
  • The New Hampshire Supreme Court refused relief to the Trustees.
  • The U.S. Supreme Court, however, reversed the New Hampshire Supreme Court.  It held that the initial charter creating the college was a contract with which the State of New Hampshire could not interfere, based on the Contracts Clause of the Constitution.

Trustees of Dartmouth College v. Woodward Case Brief

Statement of the Facts:

Dartmouth College was chartered before the American Revolution.  After the Revolution, it remained a privately funded institution.  The State of New Hampshire, in 1816, attempted to change Dartmouth College to a state university.  Specifically, the legislature changed the college’s corporate charter such that the control once vested in the Trustees of the college was changed to the State governor.  It did so by adding new appointees to the Trustee board.  In order to regain authority over the college, the Trustees sued Woodward, a Trustee who sided with those appointed by the State.

The suit alleged that the legislature’s action violated the Trustees’ freedom to contract; and it asked the court to compel Woodward to return the college’s record, books, and seal; and to pay damages.

Procedural History:

  • The New Hampshire Supreme Court ruled against the Trustees.
  • The U.S. Supreme Court took the case on a writ of error.

Issue and Holding:

Does the Constitution’s Contracts Clause apply to private as well as public contracts?  Yes.

Judgment:

The decision of the New Hampshire Supreme Court is reversed.

Rule of Law or Legal Principle Applied:

A charter, such as the one granted by the British Crown to Dartmouth College, is a contract.  Under the Constitution, no State shall make any law impairing the obligations of contracts.

Reasoning:

The Court noted first that giving respect to contracts made in the U.S. is necessary to the functioning of the Republic.  The Court went on to find that Dartmouth College’s corporate charter was a “contract” between parties – the British Crown and the Trustees – with which the New Hampshire legislature could not interfere.  Despite the fact that the United States were no longer royal colonies, that did not change the fact that there was a valid contract, which is protected by the Constitution’s Contracts Clause.  New Hampshire commissioned the charter after the Revolution.  But, that did not change the school into a public institution.

Significance:

Trustees of Dartmouth College v. Woodward finds precedent in Fletcher v. Peck, which held that valid contracts (even if illegally obtained) cannot be invalidated by a government entity.  The decision was not popular in its day, but it is now seen as an important early Supreme Court decision that strengthened the Contracts Clause and limited the government’s power to interfere with private charters.

Student Resources:

Read the Full Court Opinion

 

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