William Burnham Woods

William Burnham Woods (August 3, 1824 – May 14, 1887) was an American jurist who served as an associate justice of the Supreme Court of the United States. An appointee of President Rutherford B. Hayes, he served from 1881 until 1887. He wrote the majority opinion in United States v. Harris, involving the constitutionality of the Ku Klux Klan Act, and Presser v. Illinois, involving the application of the Second Amendment to the states; both cases adopted a narrow interpretation of the Fourteenth Amendment. He dissented rarely and wrote mostly uncontroversial opinions.

Born in Newark, Ohio, Woods received his degree from Yale University. He practiced law in Newark and entered politics, soon rising to be the speaker of the Ohio House of Representatives. A Democrat, he initially opposed the Lincoln 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 a brevet 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, President Ulysses S. Grant appointed Woods a circuit judge for the Fifth Circuit, which covered six Southern states. In the Slaughter-House Cases and United 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 the Senate 39–8. On the Court, he was a diligent worker who wrote more opinions than any other associate justice during his six-year tenure. He was struck ill in spring 1886 and died in 1887.

Early life, education, and career William Burnham Woods was born in Newark, Ohio, on August 3, 1824, to Ezekiel S. Woods, a Kentucky-born merchant and farmer, and Sarah Burnham Woods, who was from New England. He attended Western Reserve College (now Case Western Reserve University) before transferring to Yale University, from which he graduated as valedictorian in 1845. After returning to Newark, he studied law under the tutelage of S. D. King, a prominent lawyer; the two became partners after Woods was admitted to the bar in 1847. While some evidence suggests that he was at first a Whig, he later became a member of the Democratic Party. At first Woods staunchly opposed the policies of the Lincoln administration, but when the Civil War broke out, he supported the Union cause, vowing to stand by the federal government "in sunshine or storm, in peace or war, right or wrong". In February 1862, he joined the 76th Ohio Infantry Regiment as a lieutenant colonel, becoming colonel in September when the previous colonel – his brother, Charles R. Woods – was promoted to brigadier general. and participated in the Grand Review of the Armies in Washington.

In Bertonneau v. Board of Directors of City Schools, an 1878 school segregation decision, Woods offered an early formulation of what became the separate-but-equal doctrine. 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. Hayes, however, nominated John Marshall Harlan instead.

Supreme Court service alt=Nine Supreme Court justices in their judicial robes; five are seated in the front row and four are standing behind them. 1886 group photograph of the Supreme Court justices. Woods is in the top row, leftmost. Woods remained on the Supreme Court until his death in 1887. His jurisprudence was generally nationalistic: he joined the majority in Juilliard v. Greenman to hold that the federal government could lawfully print paper money, and he dissented when the Court held in United States v. Lee that individuals could sue federal officers. He wrote for an eight-justice majority in United States v. Harris (1883) that the Fourteenth Amendment did not authorize laws that prohibit individuals from interfering with other individuals' civil rights. in which Woods joined the majority in holding much of the Civil Rights Act of 1875 unconstitutional. In Presser v. Illinois, involving a man convicted of violating Illinois law by carrying firearms as part of a private militia, Woods's opinion for a unanimous Court held that the Second Amendment applied only to the federal government; His condition seemed to be improving during a lengthy stay in California, but it soon worsened. President Grover Cleveland nominated Lucius Quintus Cincinnatus Lamar to replace him.

Legacy The scholar Louis 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". A 1970 survey of law professors rated him "below average", 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". 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". According to Timothy L. Hall, "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".