William Burnham Woods.
Published in 1885, the print Our Overworked Supreme Court depicts Supreme Court justices Woods, Blatchford, Harlan, Gray, Miller, Field, Waite, Bradley, and Matthews surrounded by paperwork for cases.
Portrait of William Burnham Woods.
Justice William Burnham Woods in the 1870s.
Colonel William Burnham Woods.
10900 Euclid Ave, Cleveland, Ohio 44106, United States
Case Western Reserve University.
New Haven, Connecticut 06520, United States
William Woods attended three years of college at Western Reserve College (later Case Western Reserve University) before transferring to Yale and graduating valedictorian of his class in 1845. Thereafter, he returned to Newark and studied law with S. D. King, eventually being admitted to the Ohio bar in 1847 and becoming Mr. King’s partner.
In 1856 Mr. Woods won the election for mayor of Newark. The following year his political experience moved to the state level when he was elected on the Democratic ticket to serve as a representative in the Ohio legislature. Almost immediately, he won the post of Speaker of the House and held it until elections in 1860 put the Republicans in the majority, upon which he became the minority leader.
William Woods did not welcome the onset of the Civil War, but he soon devoted himself to the Union cause, following his younger brother, Charles R. Woods, who would become a well-regarded field general in the Union army, into military service. He entered the war as a lieutenant colonel, serving with the 76th Ohio Volunteer Regiment in 1862, and saw significant action at Shiloh, Vicksburg, and on General William Sherman’s long march through Georgia. He impressed virtually everyone with whom he served, earning the favorable regard of Generals Sherman and Ulysses S. Grant. By the end of the war he had been promoted to the rank of breveted major general.
After the war Mr. Woods was posted to Alabama, and when he left military service he chose to remain there. His brother-in-law had already achieved prominence as U.S. senator from Alabama and Woods decided to settle in Bentonville, where he planted cotton and practiced law. Now a Republican, Mr. Woods was elected to the Middle Chancery Court in 1868 and served two years before President Grant appointed him a judge on the U.S. Fifth Circuit Court of Appeals in 1869.
As a circuit judge, the most important cases to come before William Woods were the cluster of cases that eventually became well known as the Slaughterhouse Cases. Supreme Court justices of the time handled not only the cases before the Court, but also served as circuit judges in the federal circuit courts of appeal. Associate Justice Joseph P. Bradley served for a time as a judge on the Fifth Circuit, and in this capacity he and William Woods presided over the Slaughterhouse Cases. The three suits underlying what would become the Slaughterhouse Cases involved a Louisiana law that had granted a monopoly in the slaughterhouse business in and around New Orleans to a favored enterprise. The competitors, represented ably by former Supreme Court justice John Archibald Campbell, challenged the legislative monopoly and wielded the newly ratified Fourteenth Amendment as their chief weapon against the monopoly. They argued that the government-backed monopoly deprived them of the "privileges and immunities" to which they were entitled as United States citizens, as well as due process and equal protection of law. Justice Bradley and Judge Woods agreed that the monopoly violated the Fourteenth Amendment, giving the text of the Constitution an expansive reading that would shortly be repudiated by the U.S. Supreme Court when deciding the Slaughterhouse Cases (1873).
William Woods spent a little more than a decade traveling across the states covered by the Fifth Circuit, mastering the laws of these states, including the intricacies of Louisiana civil law, and generally earning the respect of southerners who found him to be a fair and hardworking judge. He eventually moved to Atlanta, Georgia, in 1877 and won a similar reputation there.
Upon the resignation of Justice William Strong from the Supreme Court in 1880, President Rutherford B. Hayes was eager to find a southerner to replace him. He shortly found himself inundated with expressions of support for William Woods as a replacement. Former justice John Archibald Campbell and General William Sherman were among the prominent voices raised in support of Mr. Woods’s candidacy for the Supreme Court. Inevitably, there were scattered suggestions that Woods was not a true southerner but rather a carpetbagger. Nevertheless, Mr. Hayes found William Woods’s experience as a Fifth Circuit judge and his service to the Union as a military officer ample reason to forward his nomination to the Senate on December 15, 1880, the day after Mr. Strong’s resignation. The Senate confirmed the appointment before the close of the year.
Two cases highlighted Mr. Woods’s Supreme Court career. In United States v. Harris (1883), William Woods penned the majority’s decision declaring the Ku Klux Klan Act of 1871 unconstitutional. The act, adopted by Congress to protect the civil rights of African Americans from terrorist organizations such as the Klan, made it a crime for two or more people to conspire or use disguises to deprive another person of the equal privileges and immunities of the laws. The law was defended as an appropriate means of enforcing the protections provided by the Constitution’s Reconstruction Amendments, particularly the Fourteenth Amendment, which prevents states from depriving persons of equal protection or due process of law. For the majority, however, Mr. Woods’s opinion concluded that the Fourteenth Amendment prohibited only official acts of racial discrimination and not private conduct that might deprive a person of life, liberty, or property. If the Klan’s campaign of violence against blacks was to be ended, then states - rather than the federal government - would have to end it; Congress had no power to intrude on the province of states in enforcing the law.
In Presser v. Illinois (1886), William Woods again wrote for a majority of the Court, a case involving the Second Amendment’s right to bear arms. An Illinois statute made it a crime to parade with arms except in an official state militia. When a citizen was prosecuted for leading an armed fraternal organization in a parade, he argued that the Illinois law violated the Second Amendment. Mr. Woods, writing for a unanimous Court, rejected this claim. The Second Amendment, he reasoned, prohibited only federal attempts to restrict the ability of citizens to bear arms. Since the Presser case involved a state gun control law, the Second Amendment had no application. William Woods’s tenure on the Court proved to be quite brief, because of his illness in the spring of 1886.
Initially, Mr. Woods was a committed Democrat and resisted the growing Republican tide. However, in 1863 he joined the ranks of the Republican Party of the United States. At first, he also opposed the Civil War but then acknowledged the necessity of a Northern victory. Besides, he was not a proponent of slavery.
In 1847 Mr. Woods married Anne E. Warner. They were the parents of two children, a boy and a girl.