DARTMOUTH COLLEGE CASE

DARTMOUTH COLLEGE CASE. In 1819 the U.S. Supreme Court, in Trustees of Dartmouth College v. Woodward, 4 Wheaton 518, extended judicial interpretation by declaring private-corporation charters to be contracts and hence, by the contract clause of the Constitution of the United States, immune from impairment by state legislative action. Circumstances had aligned Republicans against Federalists and egalitarianism against religious establishment to complicate the education squabble. On 26 August 1815 the self-perpetuating board of trustees established under the charter of 1769 deposed the president of Dartmouth, John Wheelock. New Hampshire legislative enactments presently altered the charter and brought the institution under state control by enlarging the board; by creating a board of overseers appointed by the legislature, with veto on trustee action; and by changing its name to Dartmouth University. The college sued William H. Woodward, an adherent of the university faction and former secretary-treasurer of the college, for recovery of the charter, the seal, and other documents. After a state court decision favorable to the university faction, Daniel Webster argued the case before the Supreme Court. Chief Justice John Marshall's opinion held that the New Hampshire law was invalid because it impaired contractual obligations. This decision freed existing corporations from control by the states that created them and became a bulwark of laissez faire and a boon to corporate development. Control was later largely restored by (a) state legislation reserving the right to alter or repeal subsequent charters and (b) judicial decisions forbidding legislatures to grant, by charter, rights that menace the community or to surrender, by charter, its duty under the police power to protect the life, safety, and morals of the community.

BIBLIOGRAPHY

Johnson, Herbert Alan. The Chief Justiceship of John Marshall, 1801–1835. Columbia: University of South Carolina Press, 1997.

Tobias, Marilyn. Old Dartmouth on Trial: The Transformation of the Academic Community in Nineteenth-Century America. New York: New York University Press, 1982.

L. EthanEllis/a. r.

See alsoEducation, Higher: Colleges and Universities ; Fletcher v. Peck ; Judiciary Act of 1789 ; Universities, State .

Dartmouth College Case (1819). In Dartmouth College v. Woodward, the U.S. Supreme Court extended the scope of the contract clause of the Constitution (article 1, section 10). In 1769, the royal governor of New Hampshire, acting in the name of the English crown, granted Dartmouth College a charter to operate as a private institution under the administration of a group of trustees. In 1816, however, the New Hampshire legislature passed several laws that transformed Dartmouth from a private to a public college, subject to inspection by the state.

The college, claiming that its charter rights had been violated, took the case to court, with Daniel Webster, a Dartmouth graduate, as its chief attorney. At this time, it was understood that state legislatures could regulate corporations, but that private property could not be taken from individuals by state action without proper compensation. Writing for the majority, Chief Justice John Marshall ruled that the college was a “private eleemosynary institution” and that the 1769 charter was a valid contract between the state and the original donors to the institution. By voiding the legislation that had transformed Dartmouth into a public institution, Marshall not only strengthened the contract clause of the Constitution, but also expanded the federal judiciary's role in overseeing state legislative action affecting property rights.
See also Economic Regulation.

Bibliography

G. Edward White , The Marshall Court and the Culture of Change, 1815–1835, 1988.

Paul Clemens

Dartmouth College Case decided by the U.S. Supreme Court in 1819. The legislature of New Hampshire, in 1816, without the consent of the college trustees, amended the charter of 1769 to make Dartmouth College public. The trustees brought suit. Daniel Webster argued successfully that the amendment violated the Constitution because the state had impaired "the obligation of a contract." The opinion of the court, delivered by Chief Justice John Marshall, was that a charter was in effect inviolable. The decision made the contract clause of the Constitution a powerful instrument for the judicial protection of property rights against state abridgment. In 1837, Chief Justice Taney , while not challenging the basic principle, ruled in the Charles River Bridge Case that a legislative charter must be construed narrowly and a corporation could claim no implied rights beyond the specific terms of a grant.