Dartmouth College v. Woodward 1819 – Flashcards

In 1769, the King George III of England granted a corporate charter to create a seminary for educating Indians. This charter formed what would become Dartmouth College; it spelled out the purpose of the school, set up the structure to govern it, and gave land to the college. In 1779, John Wheelock is the President of the College, he clashes with the Board of Trustees over 36 years. Wheelock and his supporters are Presbyterians and Republicans, the Board of Trustees are Congregationalists and Federalists. The board removes Wheelock as president of the college. In 1816, Jeffersonian Republicans take over the state, and pass legislation that change the original charter and make Dartmouth College a public university. Changes how trustees are selected, adds for new trustees. Also took away seal, buildings and charter. The new trustees oust the old trustees, who are locked out of college buildings. The old trustees (Daniel Webster) sue the state approved secretary of the new trustees, William Woodward, and argue that the legislature that turned Dartmouth public violated the Constitution as it infringed on a previously held contract.

Was it legal for the State of New Hampshire to take over Dartmouth College and make it into a public institution?

Contracts Clause / Article 1, Section 10, of the Constitution prevented a state from "impairing" (that is, weakening or canceling) a contract.

By a 5-1 margin, the court agreed with Dartmouth College that it was unconstitutional for New Hampshire to pass legislature to turn the college into a public university, as states cannot interfere with contracts.

Chief Justice Marshall wrote the majority opinion. Under contracts clause, a corporate charter is a public contract, may not be impaired by legislative enactment He said that the charter was, in essence, a contract between the King and the trustees. Even though we were no longer a royal colony, the contract is still valid because the Constitution says that a state cannot pass laws to impair a contract. Although no one had financial interest vested, Marshall held that the case fell within the spirit of the Constitution.

Doctrines: — Contract Clause applies to public as well as private contracts — A grant is a public contract with implied contract that it will not be rescinded — A corporate charter is a public contract whose terms may not be unilaterally changed by the state The opinion reaffirmed Marshall's belief in the sanctity of a contract (also seen in Fletcher v. Peck) as necessary to the functioning of a republic (in the absence of royal rule, contracts rule)

The alternate solution could have been the decision that a corporate charter is not a public contract, and is therefore subjective to legislative action of states.