Questions and Answers
What was granted to create a seminary for educating Indians in 1769?
What did the charter of Dartmouth College include?
Who was the President of Dartmouth College in 1779?
John Wheelock
The Board of Trustees at Dartmouth College supported Montgomery Wheelock.
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What did the New Hampshire legislation change about Dartmouth College in 1816?
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What clause of the US Constitution was at issue in Dartmouth College v. Woodward?
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The Supreme Court ruled in favor of New Hampshire in the Dartmouth College case.
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What was the majority opinion's reasoning regarding corporate charters?
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Match the doctrines established in Dartmouth College v. Woodward:
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What was an alternative solution to the ruling in the Dartmouth case?
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Study Notes
Facts
- King George III granted a corporate charter in 1769 to establish a seminary for educating Indians, leading to the creation of Dartmouth College.
- The charter defined the school's purpose, governance structure, and allocated land.
- John Wheelock served as president from 1779, facing opposition from the Board of Trustees over 36 years, representing differing religious and political affiliations.
- In 1816, following the rise of Jeffersonian Republicans, the New Hampshire legislature amended the original charter, transforming Dartmouth College into a public university.
- New legislation altered trustee selection, added new trustees, and removed traditional symbols, leading to the ousting of old trustees.
Statute or Government Action in Dispute
- The legality of New Hampshire's takeover of Dartmouth College and its transition to a public institution was questioned.
Provision of the US Constitution at Issue
- The Contracts Clause (Article 1, Section 10) prohibits states from impairing existing contracts, which was central to the case.
Outcome
- The court ruled in a 5-1 decision that New Hampshire's actions to convert Dartmouth into a public university were unconstitutional, affirming that states cannot interfere with contracts.
Reasoning of the Majority
- Chief Justice Marshall asserted that a corporate charter constitutes a public contract, which legislative actions cannot impair.
- He maintained that the original charter, established between the King and the trustees, remained valid post-royal colony era due to constitutional protections against legislative interference, despite a lack of financial interest.
Major Doctrine or Doctrines
- Key doctrines established include:
- The Contracts Clause applies to both public and private contracts.
- A grant is inherently a public contract with an implied assurance against rescission.
- A corporate charter is recognized as a public contract that cannot be unilaterally modified by the state.
- The opinion reinforced the significance of contracts within a republic, similar to views expressed in Fletcher v. Peck.
Alternative Solution
- An alternative ruling could have classified a corporate charter as a non-public contract, allowing legislative modifications by states.
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Description
Explore key facts and legal implications of the Dartmouth College v. Woodward case from 1819. This set of flashcards will help you understand the historical context, the conflicting interests between the college leadership and its Board of Trustees, and the lasting impact of this landmark decision on educational institutions.