William Burnham Woods | |
|---|---|
 | |
| Associate Justice of the Supreme Court of the United States | |
| In office January 5, 1881 – May 14, 1887 | |
| Nominated by | Rutherford Hayes |
| Preceded by | William Strong |
| Succeeded by | Lucius Lamar |
| Judge of theUnited States Circuit Court for the Fifth Circuit | |
| In office December 22, 1869 – December 21, 1880 | |
| Nominated by | Ulysses Grant |
| Preceded by | Seat established |
| Succeeded by | Don Pardee |
| Personal details | |
| Born | (1824-08-03)August 3, 1824 Newark, Ohio, U.S. |
| Died | May 14, 1887(1887-05-14) (aged 62) Washington, D.C., U.S. |
| Party | Democratic (before 1863) Republican (1863–1887) |
| Relatives | Charles R. Woods (brother) |
| Education | Yale University (BA) |
| Signature |  |
| Military service | |
| Allegiance | |
| Branch/service |  United States Army.svg) Union Army |
| Years of service | 1862–1866 |
| Rank |  Brigadier General BrevetMajor General |
| Commands | 76th Ohio Infantry XV Corps |
| Battles/wars | |
William Burnham Woods (August 3, 1824 – May 14, 1887) was an American jurist who served as an associate justice of theSupreme Court of the United States. An appointee of PresidentRutherford B. Hayes, he served from 1881 until 1887. He wrote the majority opinion inUnited States v. Harris, involving the constitutionality of theKu Klux Klan Act, andPresser v. Illinois, involving the application of theSecond Amendment to the states; both cases adopted a narrow interpretation of theFourteenth Amendment. He dissented rarely and wrote mostly uncontroversial opinions.
Born inNewark, Ohio, Woods received his degree fromYale University. He practiced law in Newark and entered politics, soon rising to be the speaker of theOhio House of Representatives. A Democrat, he initially opposed theLincoln administration's policies but supported the Union once the Civil War broke out. He joined the Union army as an officer, participating in a number of battles; after his discharge as abrevet major general in 1866, he settled in Alabama, where he practiced law and engaged in commercial activities. In 1868, he was elected to an Alabama state court on the Republican ticket.
In 1869, PresidentUlysses S. Grant appointed Woods acircuit judge for the Fifth Circuit, which covered six Southern states. In theSlaughter-House Cases andUnited States v. Cruikshank, he favored a broad interpretation of the Fourteenth Amendment that contrasted with the narrower one he supported on the Supreme Court. In another case, he upheld "separate but equal" schools. Hayes nominated Woods to the Supreme Court in 1880, and he was confirmed by theSenate 39–8. On the Court, he was a diligent worker who wrote more opinions than any otherassociate justice during his six-year tenure. He was struck ill in spring 1886 and died in 1887.
William Burnham Woods[1]: 221 was born inNewark, Ohio, on August 3, 1824, to Ezekiel S. Woods, a Kentucky-born merchant and farmer, and Sarah Burnham Woods, who was from New England.[2]: 1328 He attended Western Reserve College (nowCase Western Reserve University)[3]: 142 before transferring toYale University, from which he graduated asvaledictorian in 1845.[4]: 179 After returning to Newark, he studied law under the tutelage of S. D. King, a prominent lawyer; the two becamepartners after Woods wasadmitted to the bar in 1847.[2]: 1328 Woods took an interest in politics in the 1850s.[5]: 31 While some evidence suggests that he was at first aWhig, he later became a member of theDemocratic Party.[5]: 31 In 1855, he married Anne E. Warner, with whom he had two children.[1]: 221
Woods became Newark's mayor in 1856, and the following year he was elected as a Democrat to theOhio House of Representatives, immediately becomingits speaker.[2]: 1328 [6]: 572 At first Woods staunchly opposed the policies of theLincoln administration, but when theCivil War broke out, he supported the Union cause,[5]: 31 [7]: 12 vowing to stand by the federal government "in sunshine or storm, in peace or war, right or wrong".[8]: 13 In February 1862, he joined the76th Ohio Infantry Regiment as alieutenant colonel, becomingcolonel in September when the previous colonel – his brother,Charles R. Woods – was promoted tobrigadier general.[7]: 12 [6]: 572
Woods served in theBattle of Shiloh, theSiege of Vicksburg, andSherman's March.[5]: 31 He was made brigadier general in 1865[9]: 899 and participated in theGrand Review of the Armies in Washington.[1]: 222 Just before his discharge in February 1866, he wasbrevetted amajor general at the recommendation of Generals Sherman,Ulysses S. Grant, andJohn A. Logan.[9]: 899 [1]: 222 After being mustered out, Woods settled in Alabama, where he had been serving; there he practiced law, involved himself in cotton production, and invested inironworks.[5]: 31–32 [2]: 1329 He had by this time become a Republican, and in 1868 he was elected on the Republican ticketchancellor of the middle chancery division of Alabama.[9]: 899
Whenan 1869 judicial reorganization law created nine newcircuit judgeships,[5]: 32 President Grant appointed Woods to be circuit judge for the Fifth Circuit, which comprised Alabama, Florida, Georgia, Louisiana, Mississippi, and Texas.[7]: 10, 12 He was sworn in on December 22, 1869.[7]: 12 Little information is available as to why the President selected Woods, but Thomas E. Baynes Jr. suggests that his Republican politics, his military service with Grant, and the fact that his brother-in-lawWillard Warner was a U.S. Senator all played a role.[1]: 222
Woods and JusticeJoseph P. Bradley (who wasriding circuit) heard theSlaughter-House Cases in 1870; in an opinion by Bradley, they both agreed that theFourteenth Amendment'sPrivileges or Immunities Clause should be interpreted broadly to protect civil rights associated with U.S. citizenship against infringement by the states.[7]: 13 In another privileges-and-immunities decision,United States v. Hall (1871), Woods sustained an indictment under theEnforcement Act of 1870, holding that the Fourteenth Amendment gave Congress the power to protect the freedoms of speech and of assembly through legislation.[2]: 1332 [7]: 13–14 The Supreme Court's 1873 ruling in theSlaughter-House Cases rejected Bradley and Woods's broader interpretation of the Fourteenth Amendment.[7]: 14 In the 1874 Enforcement Act case ofUnited States v. Cruikshank, Bradley dismissed federal charges against the perpetrators of theColfax massacre, in which scores of African-American men were killed, but Woods dissented without an opinion; when the case reached the Supreme Court bycertificate of division, it affirmed Bradley's decision.[7]: 14–15 [10]: 35–36
InBertonneau v. Board of Directors of City Schools, an 1878school segregation decision, Woods offered an early formulation of what became theseparate-but-equal doctrine.[2]: 1333 Rejecting the arguments of African-American children who sought admission to an whites-only public school in New Orleans, Woods emphasized that a blacks-only school was available and that the plaintiffs had not claimed it was inferior.[11]: 29–30 [12]: 522 He argued that while states were obliged to afford "equal privileges and advantages to both races", they could otherwise manage schools in whatever way they thought best.[11]: 30 For Woods, the substance of the case was that "[w]hite children and colored children are compelled to attend different schools. That is all."[2]: 1333 In its notorious 1896 decision inPlessy v. Ferguson endorsing the separate-but-equal doctrine, the Supreme Court citedBertonneau and other similar decisions that had upheld racial segregation in public schools.[12]: 489, 522
Woods expended considerable effort to learnLouisiana law, which was especially complicated due to its French and Spanish roots.[2]: 1330 He prepared four volumes ofreports of cases decided by the circuit court.[7]: 12 In the aftermath of the contested1876 presidential election, he avoided becoming involved in a dispute over the eligibility of a Florida Republican elector who had attempted to resign another federal office by writing to Woods.[2]: 1331 Woods moved toAtlanta, Georgia, in 1877.[2]: 1331
When a U.S. Supreme Court vacancy arose in 1877, many political figures urged PresidentRutherford B. Hayes to nominate Woods.[5]: 33–34 These included Ohio notables (such asJames A. Garfield andJohn Sherman), Southern Republicans, and local business interests, but Southern Democrats – for instanceJohn A. Campbell,Lucius Q. C. Lamar, andJohn T. Morgan – advocated for him as well; Lamar, a former Confederate official, wrote that Woods "would be more acceptable to our people than any of those most likely to get the position".[5]: 33–34 [13]: 204–205 Hayes, however, nominatedJohn Marshall Harlan instead.[5]: 34
In December 1880, the press reported that JusticeWilliam Strong intended to resign.[5]: 34–35 Justice Bradley wanted to take his place ascircuit justice for the Third Circuit, which would leave the Fifth Circuit position vacant—making it preferable for Strong's replacement to have experience with Louisiana and Texas law.[2]: 1333 [5]: 35 Additionally, Woods was "precisely the kind of candidate Hayes sought to help bind bitter sectional wounds", according to the legal scholarHenry J. Abraham: he was born in the North yet lived in the South (without being thought of as acarpetbagger), and he was a Republican yet was trusted and supported by Southern Democrats.[14]: 102 [15]: 29 Strong submitted his letter of resignation on December 14, and the following day Hayes nominated Woods to take his place.[5]: 35 Despite concerns that too many justices from Ohio were being appointed (Chase,Waite,Swayne, Woods, and the rumored next nomineeStanley Matthews were all associated with that state), the Senate confirmed him by a vote of 39 to 8[5]: 35–36 on December 21, 1880.[10]: 111 He was sworn in on January 5, 1881.[16]: 618
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Woods remained on the Supreme Court until his death in 1887.[9]: 899 A hard worker on a Court deluged with cases, he wrote more opinions during his tenure than any other associate justice.[1]: 225 Most of his opinions for the Court were in uncontroversial cases, often involving real property, patents, taxation, commerce, municipal law, trusts, or corporations.[5]: 37 He participated in nearly 1,500 cases but dissented only eight times, and Baynes states that he "clearly should be characterized with the majority of the Court".[1]: 225 [17]: 667 His jurisprudence was generally nationalistic: he joined the majority inJuilliard v. Greenman to hold that the federal government could lawfully print paper money, and he dissented when the Court held inUnited States v. Lee that individuals could sue federal officers.[2]: 1334 InElk v. Wilkins, he joined a dissent by Harlan when the majority held thatNative Americans were not U.S. citizens.[2]: 1335–1336
Woods interpreted the Fourteenth Amendment more narrowly and conservatively on the Supreme Court than he had on the Fifth Circuit.[16]: 618 [18]: 1097–1098 He wrote for an eight-justice majority inUnited States v. Harris (1883) that the Fourteenth Amendment did not authorize laws that prohibit individuals from interfering with other individuals' civil rights.[1]: 225 The decision, which involved defendants charged with breaking into a jail and beating four black prisoners (in one case to death), held that theKu Klux Klan Act exceeded Congress's power.[16]: 618 Harris set the stage for the Court's 8–1 decision later that year in theCivil Rights Cases,[15]: 159 in which Woods joined the majority in holding much of theCivil Rights Act of 1875 unconstitutional.[19]: 142 InPresser v. Illinois, involving a man convicted of violating Illinois law by carrying firearms as part of a privatemilitia, Woods's opinion for a unanimous Court held that theSecond Amendment applied only to the federal government;[16]: 619 it "limited the possibilities of applying the Bill of Rights to the states through the Fourteenth Amendment", according to the legal scholarRobert J. Cottrol.[18]: 1098
Woods became suddenly ill in the spring of 1886[5]: 38 and did not participate in the Court's 1886–87 term;[15]: 13 the details of his illness are not known.[20]: 62 His condition seemed to be improving during a lengthy stay in California, but it soon worsened.[5]: 38 Woods died aged 62 on May 14, 1887, in Washington, D.C.,[16]: 618 and he was buried at the Cedar Hill Cemetery in Newark, Ohio.[21]: 40 PresidentGrover Cleveland nominatedLucius Quintus Cincinnatus Lamar to replace him.[19]: 74
The scholarLouis Filler began a 1969 essay on Woods by describing him as "one of the least known of all the Justices who have served on the United States Supreme Court".[2]: 1327 A 1970 survey of law professors rated him "below average",[5]: 31 but the legal scholar D. Grier Stephenson suggests that this rating "probably results more from general unfamiliarity than from a careful appraisal of his work".[15]: 55 The historian Stephen Cresswell attributes Woods's low historical reputation to his brief tenure, the frequency of his votes with the majority, and perceptions that he was a carpetbagger with a "muddled judicial philosophy".[16]: 619 According to Timothy L. Hall, "[m]ore a follower than a leader, more an echo of the reverberating ideas of others than an original thinker in his own right, his brief years on the Court climaxed a life too far removed from the center of events to warrant more than passing historical mention".[4]: 181
| Legal offices | ||
|---|---|---|
| New seat | Judge of theUnited States Circuit Courts for the Fifth Circuit 1869–1880 | Succeeded by |
| Preceded by | Associate Justice of the Supreme Court of the United States 1881–1887 | Succeeded by |
| International | |
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| National | |
| Other | |
