{"id":54762,"date":"2025-03-03T11:59:44","date_gmt":"2025-03-03T16:59:44","guid":{"rendered":"https:\/\/content.findlaw-admin.com\/ability-legal\/supreme\/supreme-court-insights\/dartmouth-college-v-woodward-case-summary.html"},"modified":"2025-03-03T12:06:22","modified_gmt":"2025-03-03T17:06:22","slug":"dartmouth-college-v-woodward-case-summary","status":"publish","type":"supreme","link":"https:\/\/supreme.findlaw.com\/supreme-court-insights\/dartmouth-college-v-woodward-case-summary.html","title":{"rendered":"Dartmouth College v. Woodward Case Summary"},"content":{"rendered":"\n
\n \n
\n

Dartmouth College v. Woodward Case Summary<\/h1>\n
\n
\n By Susan Buckner, J.D.<\/a> | Legally reviewed by Laura Temme, Esq.<\/a>\n | Last reviewed\n
\n \n <\/i>\n Legally Reviewed\n <\/summary>\n\n
\n

This article has been written and reviewed for legal accuracy, clarity, and style by FindLaw\u2019s team of legal writers and attorneys<\/a> and in accordance with our editorial standards<\/a>.<\/em><\/p>\n\n <\/div>\n <\/details>\n\n

\n \n <\/i>\n Fact-Checked\n <\/summary>\n\n
\n

The last updated date refers to the last time this article was reviewed by FindLaw or one of our contributing authors<\/a>. We make every effort to keep our articles updated. For information regarding a specific legal issue affecting you, please contact an attorney in your area<\/a>.<\/em><\/p>\n\n <\/div>\n <\/details>\n<\/section>\n

\n

Dartmouth College v. Woodward was a landmark U.S. Supreme Court case in 1819 that addressed whether states could alter the charters of private corporations without their consent. The Court ruled that the charter issued by King George III to Dartmouth College was a private contract, which the New Hampshire legislature could not unilaterally amend. This decision established that the U.S. Constitution protects private contracts from state interference. <\/p>\n\n <\/div>\n\n

The United States has a long history of supporting education. Even before the nation’s founding, the King of England granted a Presbyterian minister, Eleazar Wheelock, a royal charter to establish a college “for the education of Indian [sic] and English youth in the province.” This school\u00a0eventually became Dartmouth College in New Hampshire.<\/p>\r\n

Eleazar Wheelock died in 1779. His son, John Wheelock, succeeded him as president of the board of trustees for Dartmouth College. The junior Wheelock served in that role for nearly 40 years. During his tenure, he oversaw the founding of Dartmouth Medical School.\u00a0<\/p>\r\n

Unfortunately, Wheelock had a falling out with the other trustees. In 1815, the board fired him.<\/p>\r\n

In response, Wheelock persuaded the governor of New Hampshire to amend Dartmouth College’s\u00a0charter. The change made the school a public institution (Dartmouth University) and placed control of it\u00a0in the hands of appointee William H. Woodward. Outraged, the original trustees\u00a0filed suit against Woodward.<\/p>\r\n

The case eventually reached the U.S. Supreme Court, which ruled on the dispute in 1819<\/a>.\u00a0<\/p>\r\n

Procedural History<\/h2>\r\n

The New Hampshire state court issued a conditional verdict for Woodward. The court said the acts of the New Hampshire legislature were valid if<\/i> they were not contrary to the contracts clause of the Constitution of the United States<\/a>.\u00a0<\/p>\r\n

This question was relatively novel for courts in 1815. The New Hampshire court requested a ruling from the United States Supreme Court on the issue.<\/p>\r\n

First Question: Is the Charter a Contract?<\/h2>\r\n

Chief Justice John Marshall established the U.S. Supreme Court as the arbiter of Constitutional review in\u00a0Marbury v. Madison<\/i><\/a> <\/i>(1803).\u00a0<\/p>\r\n

Writing for the majority in Dartmouth<\/i>,\u00a0Marshall agreed that a “charter” from the royal government of England\u00a0establishing Dartmouth College as a private corporation (an “eleemosynary”)\u00a0contained all the necessary elements of a contract<\/a>.<\/p>\r\n

The charter that established the college created an agreement between King George III (the “grantor”),\u00a0Eleazar Wheelock (the “grantee”),\u00a0and the trustees of the board of Dartmouth College. The terms of the charter granted the trustees governance of the college.<\/p>\r\n

The charter also\u00a0contained terms for the governance of the college that the grantor and grantee were\u00a0meant to be “perpetual.” Wheelock meant for the trustees to manage the college funds and property. Donors, in turn, expected the trustees to use their donations for that purpose and no other.<\/p>\r\n

The original charter created a private corporation with specific powers and limits on the trustees. Therefore, the Supreme Court\u00a0determined that the charter was a contract according to the law.<\/p>\r\n

Second Question: Does the U.S. Constitution Apply?<\/h2>\r\n

The Court’s next question was whether the U.S. Constitution<\/a> applied to this contract.<\/p>\r\n

The Court’s analysis distinguished between:<\/p>\r\n