Dartmouth College Case

Dartmouth College Case, officially known as Trustees of Dartmouth College v. Woodward, case brought before the United States Supreme Court in 1818 by the Dartmouth College board of trustees. In 1816 the Republican-controlled New Hampshire state legislature amended the charter of the college, originally granted in 1769 by King George III of the United Kingdom of Great Britain, placing the institution under a state board of overseers appointed by the governor and renaming it Dartmouth University. The legislative action was upheld by the state superior court, which deemed the college a public corporation subject to public control.

The college trustees, made virtually powerless, appealed the decision to the Supreme Court. They were represented by Daniel Webster, who argued that Dartmouth was not a public corporation but a “private eleemosynary institution”; that its original charter was a contract; and that it was protected by Article I, Section 10, of the U.S. Constitution forbidding the passage by any state of legislation impairing a contractual obligation. The questions at issue were whether a royal charter remained binding on a state legislature, and whether the college was a public or private corporation. The decision of the Supreme Court was handed down in 1819, when Chief Justice John Marshall reversed the state court decision and restored the original trustees to power, thus upholding Webster's position. The case was the first in which the Supreme Court held that charters were contracts protected by the Constitution. Subsequent decisions and changing legislation have altered the nature of corporate charters. The case, therefore, has less significance as a precedent than has been argued, but its symbolic importance makes it a milestone in American history.