William Burnham Woods

William Burnham Woods
Born	William Burnham Woods 3 8, 1824
Birthplace	Newark, Ohio, U.S.
Died	Template:Death date and age Washington, D.C., U.S.
Nationality	American
Occupation	Jurist, military officer, politician
Known for	Associate Justice of the Supreme Court of the United States; majority opinions in United States v. Harris and Presser v. Illinois
Education	Yale University (BA)
Awards	Brevet Major General (Union Army)

William Burnham Woods (August 3, 1824 – May 14, 1887) was an American jurist, politician, and military officer who served as an Associate Justice of the Supreme Court of the United States from 1881 until his death in 1887. Appointed by President Rutherford B. Hayes, Woods was the first Supreme Court justice appointed from a former Confederate state since the American Civil War. His path to the nation's highest court was an unusual one: born and raised in Ohio, he served in the Union Army during the Civil War, rising to the rank of brevet major general, before relocating to Alabama during Reconstruction and entering Southern politics and law. As a federal circuit judge for the Fifth Circuit under appointment by President Ulysses S. Grant, Woods initially favored a broad interpretation of the Fourteenth Amendment, but his Supreme Court opinions reflected a notably narrower reading of that provision. He authored the majority opinions in United States v. Harris (1883) and Presser v. Illinois (1886), both of which limited the scope of the Fourteenth Amendment and the federal government's power to protect individual civil rights against state action. During his six years on the Court, Woods was a prolific writer of opinions, producing more than any other associate justice during that period, though he dissented rarely and his opinions were largely uncontroversial.

Early Life

William Burnham Woods was born on August 3, 1824, in Newark, Ohio, the county seat of Licking County. His brother, Charles Robert Woods, would also go on to serve as a Union general during the Civil War. Details regarding his parents and the circumstances of his upbringing in Newark are limited in the available sources, though the Woods family was evidently well-established in central Ohio. Growing up in the antebellum Midwest, Woods came of age during a period of intense political debate over slavery, westward expansion, and the future of the American republic.

As a young man, Woods demonstrated academic aptitude and pursued higher education at one of the nation's most prestigious institutions. After completing his preparatory studies in Ohio, he enrolled at Yale University in New Haven, Connecticut, where he earned his Bachelor of Arts degree. Following his graduation from Yale, Woods returned to Newark, Ohio, to study law. He was admitted to the bar and commenced the practice of law in his hometown, where he quickly established himself as a capable attorney.

Woods entered politics in Ohio as a member of the Democratic Party, which was the dominant political force in much of the Midwest during the 1850s. He proved to be an effective political figure and rose through the ranks of state government. He was elected to the Ohio House of Representatives, where he eventually attained the position of Speaker of the House, one of the most powerful positions in Ohio state government. As a Democrat in the years leading up to the Civil War, Woods initially opposed the policies of the Lincoln administration. However, once the war began and the preservation of the Union was at stake, Woods set aside his partisan objections and committed himself fully to the Union cause.

Education

Woods received his undergraduate education at Yale University, one of the foremost institutions of higher learning in the United States, where he earned a Bachelor of Arts degree. His education at Yale placed him among a relatively small elite of American professionals who had attended one of the nation's leading colleges during the antebellum period. Upon returning to Ohio after his time at Yale, Woods studied law through the apprenticeship method common in the nineteenth century. He was admitted to the Ohio bar and began practicing law in Newark. His legal training and Yale education provided the intellectual foundation for a career that would eventually lead him to the highest court in the land.

Career

Legal and Political Career in Ohio

After being admitted to the bar, Woods practiced law in Newark, Ohio, and became active in Democratic Party politics. His legal practice and political connections enabled him to win election to the Ohio House of Representatives, where he served with distinction. He rose to become the Speaker of the Ohio House, demonstrating considerable political skill and legislative ability. As a Democrat in the 1850s, Woods was part of a political tradition that was skeptical of federal power and, in many cases, resistant to the antislavery movement that was gaining strength in the Northern states. In the period immediately preceding the Civil War, Woods opposed the Lincoln administration's policies, reflecting the views of many Ohio Democrats who were wary of Republican governance.

Civil War Service

Despite his prewar political opposition to the Lincoln administration, Woods supported the Union when the Civil War erupted in 1861. He joined the Union Army as an officer, eventually commanding the 76th Ohio Infantry regiment. Woods participated in a number of significant engagements during the war. His military service was notable for its duration and the level of responsibility he assumed. He served from 1862 to 1866, and over the course of the conflict he demonstrated sufficient leadership to earn successive promotions.

Woods rose to the rank of brigadier general and ultimately received the brevet rank of major general, one of the highest ranks in the Union Army, in recognition of his wartime service. He also held command of the XV Corps during the later stages of the war. His brother, Charles Robert Woods, similarly distinguished himself as a Union general during the conflict.

The Civil War transformed Woods politically as well as personally. Having entered the war as a Democrat, he emerged from it as a Republican, a political conversion that reflected the broader realignment taking place in American politics during the 1860s. His switch to the Republican Party, which occurred around 1863, positioned him for the postwar career that would follow.

Reconstruction-Era Career in Alabama

After his discharge from the army in 1866, Woods did not return to Ohio. Instead, he settled in Alabama, where he practiced law and engaged in various commercial activities. His decision to relocate to the South placed him among the group of Northerners who moved to the former Confederate states during Reconstruction, sometimes referred to as "carpetbaggers" by their political opponents. In Alabama, Woods continued his involvement in politics, now as a Republican. In 1868, he was elected as a chancellor (a judge of a state equity court) in Alabama on the Republican ticket, marking his entry into the Southern judicial system.

Woods's time in Alabama gave him firsthand experience with the legal, political, and social challenges of Reconstruction. The former Confederate states were undergoing dramatic changes as newly freed African Americans sought to exercise their civil and political rights, and as the federal government attempted to enforce the constitutional amendments adopted in the wake of the war. This experience would prove significant when Woods was elevated to the federal bench.

Fifth Circuit Judge

In 1869, President Ulysses S. Grant appointed Woods as a judge of the United States Circuit Court for the Fifth Circuit, which at that time covered six Southern states. He was the first appointee to the seat, which had been newly established. Woods served on the Fifth Circuit from December 22, 1869, until December 21, 1880, a tenure of more than eleven years during which he dealt with many of the most pressing legal questions of the Reconstruction era.

As a circuit judge, Woods initially adopted a broad interpretation of the Fourteenth Amendment, which had been ratified in 1868 and was designed to guarantee equal protection and due process to all citizens. In cases related to the Slaughter-House Cases and United States v. Cruikshank, Woods took positions that favored an expansive reading of the amendment's protections, arguing that it gave the federal government substantial power to protect the civil rights of individuals against infringement by both state and private actors. This broad interpretation was consistent with the goals of many Reconstruction-era Republicans who sought to use the Fourteenth Amendment as a tool for protecting the rights of freedpeople in the South.

In another notable case during his tenure on the Fifth Circuit, Woods upheld the concept of "separate but equal" schools, a legal doctrine that would later be more fully articulated by the Supreme Court in Plessy v. Ferguson (1896). This ruling foreshadowed the direction in which American jurisprudence would move on questions of racial segregation in the decades that followed.

Woods's service on the Fifth Circuit earned him a reputation as a capable and hardworking judge. His extensive experience with Southern legal issues and his demonstrated judicial ability made him a plausible candidate for elevation to the Supreme Court.

Supreme Court of the United States

In 1880, President Rutherford B. Hayes nominated Woods to serve as an Associate Justice of the Supreme Court of the United States. Woods was confirmed by the United States Senate by a vote of 39 to 8, and he took his oath of office on January 5, 1881. He succeeded Justice William Strong, and his appointment was notable as the first time since before the Civil War that a justice was appointed from a former Confederate state.

On the Supreme Court, Woods proved to be a diligent and prolific worker. During his six-year tenure, he wrote more opinions than any other associate justice, a testament to his industriousness and commitment to the Court's work. However, he dissented rarely, and the bulk of his opinions dealt with relatively uncontroversial matters of law. His judicial temperament was characterized by a preference for consensus and a reluctance to stake out positions at odds with the majority of his colleagues.

United States v. Harris (1883)

One of Woods's most significant opinions was the majority opinion in United States v. Harris (1883), which addressed the constitutionality of the Ku Klux Klan Act of 1871. The case arose from the lynching of four African American prisoners in Crockett County, Tennessee, by a mob led by R.G. Harris. The federal government prosecuted Harris and others under Section 2 of the Ku Klux Klan Act, which made it a federal crime for two or more persons to conspire to deprive any person of the equal protection of the laws.

Writing for the majority, Woods struck down the relevant section of the Ku Klux Klan Act, holding that the Fourteenth Amendment applied only to state action and did not give Congress the power to punish purely private acts of violence or discrimination. Because the mob action in the case was carried out by private individuals rather than by agents of the state, the federal government lacked the constitutional authority to prosecute them under the Fourteenth Amendment. This decision adopted a narrow interpretation of the Fourteenth Amendment that significantly limited the federal government's ability to combat racial violence by private actors in the South. The ruling was consistent with the broader trend of the Supreme Court during this period toward restricting the reach of the Reconstruction amendments.

The contrast between Woods's broad interpretation of the Fourteenth Amendment as a circuit judge and his narrow interpretation on the Supreme Court has been noted by legal historians. As a circuit judge, Woods had argued that the amendment gave the federal government expansive power to protect individual rights; as a Supreme Court justice, he adopted the "state action" doctrine that severely curtailed that power.

Presser v. Illinois (1886)

Woods also wrote the majority opinion in Presser v. Illinois (1886), another case with lasting significance for American constitutional law. The case involved Herman Presser, who had been convicted under an Illinois statute for leading an armed group through the streets of Chicago without a license from the governor. Presser challenged his conviction on the grounds that the Illinois statute violated the Second Amendment right to keep and bear arms, as well as other constitutional provisions.

In his opinion for the Court, Woods held that the Second Amendment applied only as a restriction on the federal government and did not limit the power of state governments to regulate arms and militias. This ruling affirmed the principle, previously established in Barron v. Baltimore (1833), that the Bill of Rights constrained only the federal government, not the states. Woods further held that the Fourteenth Amendment did not incorporate the Second Amendment so as to make it applicable to the states. The decision in Presser thus adopted the same narrow interpretation of the Fourteenth Amendment that characterized Woods's opinion in United States v. Harris.

Presser v. Illinois remained an important precedent in Second Amendment jurisprudence for well over a century. The case was frequently cited in debates over the extent to which the Bill of Rights applies to state and local governments, a question that was not fully resolved until the Supreme Court's decision in McDonald v. City of Chicago (2010), which incorporated the Second Amendment against the states through the Fourteenth Amendment.

Other Work on the Court

Beyond his two most notable opinions, Woods authored a large volume of decisions during his time on the Supreme Court. The majority of these dealt with routine matters of federal law, including commercial disputes, jurisdictional questions, and statutory interpretation. He did not develop a distinctive judicial philosophy or become known as a leader of any particular faction on the Court. His approach was workmanlike and pragmatic, focused more on resolving individual cases than on articulating broad constitutional principles.

Woods's reluctance to dissent and his focus on producing a high volume of opinions suggest a justice who valued institutional harmony and efficiency. While this approach limited his influence on the development of constitutional doctrine, it also meant that he contributed substantially to the Court's output during a period when the justices faced a heavy caseload.

Illness and Death

In the spring of 1886, Woods was struck by illness that progressively limited his ability to participate in the Court's work. His health continued to decline over the following months. William Burnham Woods died on May 14, 1887, in Washington, D.C., at the age of 62. He was succeeded on the Supreme Court by Lucius Q.C. Lamar, who was appointed by President Grover Cleveland.

Personal Life

Woods's personal life is not extensively documented in the available sources. His brother, Charles Robert Woods, served as a Union general during the Civil War and had a distinguished military career of his own. After the Civil War, Woods relocated from Ohio to Alabama, a move that represented a significant personal as well as professional transition. He lived in Alabama during the turbulent Reconstruction period before moving to Washington, D.C., upon his appointment to the Supreme Court.

Woods's political affiliations shifted over the course of his life. He was a Democrat before and during the early years of the Civil War, but he switched to the Republican Party around 1863, a change that reflected his evolving views on the war, slavery, and Reconstruction. This political conversion was a defining feature of his biography, as it enabled the postwar career in the Republican-dominated South that ultimately led to his appointment to the federal bench.

Recognition

Woods's military service during the Civil War earned him the brevet rank of major general, one of the highest honors bestowed upon Union officers. His appointment to the Supreme Court in 1881 was itself a significant mark of recognition, as he was selected from among the nation's jurists to serve on its highest tribunal.

While Woods is not typically ranked among the most influential or memorable Supreme Court justices, his opinions in United States v. Harris and Presser v. Illinois had lasting consequences for American constitutional law. Presser in particular remained a frequently cited precedent in Second Amendment cases for more than a century after it was decided. His career has attracted scholarly attention, particularly from historians interested in the evolution of Fourteenth Amendment jurisprudence and the legal history of Reconstruction.

Woods is included in major biographical dictionaries and reference works on the Supreme Court, including The Oxford Companion to the Supreme Court of the United States and various compilations of judicial biographies.

Legacy

William Burnham Woods's legacy in American law is shaped primarily by his role in narrowing the scope of the Fourteenth Amendment during the critical post-Reconstruction period. His opinions in United States v. Harris and Presser v. Illinois contributed to a body of Supreme Court jurisprudence that restricted the federal government's power to protect civil rights and that limited the application of the Bill of Rights to state governments. These decisions were part of a broader retreat from the goals of Reconstruction that characterized the Supreme Court in the late nineteenth century.

The "state action" doctrine that Woods articulated in United States v. Harris — the principle that the Fourteenth Amendment prohibits only discrimination by state governments, not by private individuals — became a foundational element of American constitutional law. It shaped the legal landscape for civil rights for decades and was not significantly modified until the mid-twentieth century, when Congress enacted new civil rights legislation under different constitutional authorities.

Woods's opinion in Presser v. Illinois, holding that the Second Amendment does not apply to the states, remained good law for well over a century. The question of whether the Second Amendment constrains state and local governments was not definitively resolved until the Supreme Court's 2010 decision in McDonald v. City of Chicago, which incorporated the Second Amendment against the states through the Due Process Clause of the Fourteenth Amendment — the very amendment whose scope Woods had sought to limit.

The apparent contradiction between Woods's broad interpretation of the Fourteenth Amendment as a circuit judge and his narrow interpretation as a Supreme Court justice has been a subject of scholarly inquiry. Some legal historians have examined whether this shift reflected a genuine change in Woods's constitutional views, the influence of the Supreme Court's institutional dynamics, or the broader political retreat from Reconstruction that was underway in the 1880s.

Woods's career also illustrates the complex political trajectories possible in nineteenth-century America. A Democrat who became a Republican, a Northerner who became a Southerner, and a politician who became a judge, Woods navigated some of the most dramatic transformations in American history. His life encompassed the antebellum period, the Civil War, Reconstruction, and the Gilded Age, and his judicial career reflected the evolving and often contradictory legal responses to those eras.