WOODS, WILLIAM BURNHAM

William Burnham Woods served on the U.S. Supreme Court as an associate justice from 1881 to 1887. Woods's legal career led him into politics in his native Ohio, where he was a mayor and a member of the Ohio General Assembly before the u.s. civil war. In the war, he fought on the side of the Union as a commander, and afterward he moved to Alabama where he began a judicial career in the late 1860s. President rutherford b. hayes appointed Woods to the U.S. Supreme Court, where his conservative philosophy generally favored states' rights over federal power.

Born on August 3, 1824, in Newark, Ohio, Woods was the son of a farmer. He attended Western Reserve College, graduated from Yale University in 1845, and was admitted to the Ohio bar in 1847. Over the next fourteen years, he practiced law while involving himself in the state's democratic party. He mounted a successful campaign for the mayoralty of Newark in 1856, and twice won election to the Ohio General Assembly where he served from 1857 to 1861.

When the Civil War began, Woods volunteered for an Ohio regiment. He fought for the Union in several battles, including Shiloh and Vicksburg, and gradually rose through the ranks. By the time the war was drawing to a close, he was a commander under General William T. Sherman. Woods led Sherman's troops in the brutal march to the sea in Georgia that destroyed all the cities and towns between Atlanta and Savannah.

After the war, Woods changed his life. He left Ohio and moved to Alabama, became a Republican, and commenced a judicial career. In 1868 he served as chancellor of the state's Middle Chancery Division of Alabama, which made him the presiding judge of the state's equity courts, the now-antiquated system of justice that dealt with common claims. He held the position until 1880, when his reputation prompted President ulysses s. grant to appoint him a U.S. district judge in the Fifth Circuit. Woods's judicial conservatism began to develop during this period; however, he still took a somewhat tolerant view of federal power, especially with regard to the government's power to protect civil rights.

"The rights … enumerated in the first eight … amendment[s] of the constitution of the United States are [ipso facto] fundamental privileges of the citizens of the United States … and the states are inhibited from impairing or abridging them."
—William B. Woods

In 1881 President Hayes nominated Woods to the U.S. Supreme Court. Once in the Court's

conservative majority, his judicial priorities changed. Following the Civil War, Congress had enacted new civil rights laws aimed at ending >racial discrimination; equally important to this end was the ratification of the fourteenth amendment to the U.S. Constitution in 1868. But the Supreme Court soon undermined these efforts. In 1883 it struck down provisions of the civil rights act of 1875; Woods joined in the 8 to 1 majority in the so-called civil rights cases, 109 U.S. 3, 3 S. Ct. 18, 27 L. Ed. 835.

Woods's intolerance for federal reform efforts marked his last years on the Court. Like the majority of the justices, he took a narrow view of the Fourteenth Amendment. He wrote the majority opinion in United States v. Harris, 106 U.S. 629, 1 S. Ct. 601, 16 Otto 629, 27 L. Ed. 290 (1883), which held unconstitutional a federal law protecting African Americans from the terrorist ku klux klan organization. Woods stated that such powers properly belonged to states rather than the federal government. He died on May 14, 1887, in Washington D.C.

Woods, William Burnham (b. Newark, Ohio, 3 August 1824; d. Washington, D.C., 14 May 1887; interred Cedar Hill Cemetery, Newark), associate justice, 1881–1887. Appointed to the Court by President Rutherford B. Hayes in 1880, Justice William B. Woods served until his death in 1887. During his brief tenure, Woods was part of the Court's mainstream that gave a narrow reading to the Civil War Amendments, particularly the Fourteenth. His most important opinions restricted congressional ability to protect individuals from private infringement of civil rights and rejected the applicability of the Bill of Rights to the states.

William B. Woods was the son of Ezekiel S. Woods, a farmer and merchant, and Sarah Burnham. He graduated from Yale College and clerked with S. D. King, an Ohio attorney; in 1847 he was admitted to Ohio's bar. Active in the state's Democratic party before the Civil War, he served in the state legislature on the eve of the conflict. During the war he served in an Ohio volunteer regiment and rose to the rank of brevet major general.

After the war, Woods settled in Alabama and switched his political allegiances to the Republican party. He served in that state's chancery court system, developing an expertise in equity, for which he would later be noted in the federal courts. In 1869 President Ulysses S. Grant appointed him to the Fifth Circuit Court, where he initially took a more expansive view of the guarantees provided by the Fourteenth Amendment than he would later on the Supreme Court. While on the Fifth Circuit he voted to strike down government mandated monopoly as violative of the Fourteenth Amendment's Privileges or Immunities Clause. He also interpreted that clause as allowing the federal government to punish private violations of civil rights.

After his appointment to the Supreme Court in 1881, Woods' view of the Fourteenth Amendment grew more conservative. He joined with the majority in the Civil Rights Cases to strike down the Civil Rights Act of 1875 as exceeding federal power.

His two most significant opinions involved the Fourteenth Amendment. In United States v. Harris (1883), he struck down the Ku Klux Klan Act of 1871 on the grounds that protection of individuals from private conspiracies was a state not a federal function. In another opinion, Presser v. Illinois (1886), Woods limited the possibilities of applying the Bill of Rights to the states through the Fourteenth Amendment. In Presser, which involved an Illinois statute that prohibited private citizens from parading while armed, Woods held that the Second Amendment limited federal but not state action.

Justice Woods' jurisprudence reflected a concern with maintaining state prerogative and limiting federal power. That concern played a significant role in helping to limit the ability of the Fourteenth Amendment to act as a vehicle to protect individual rights.

Bibliography

L. Filler , William B. Woods, in The Justices of the Supreme Court of the United States, 1789–1969, edited by Leon M. Friedman and Fred L. Israel, vol. 2 (1969), pp. 1327–1336.

Robert J. Cottrol