William Burnham Woods
William Burnham Woods, politician and U.S. Supreme Court justice, was born in Newark, Ohio. Woods started his education at Western Reserve College (now Case Western Reserve University) in Hudson, Ohio, but moved on to Yale College, where he took his degree in 1845 with honors. After college he returned to Newark and learned law by clerking with a prominent local lawyer, S. D. King, with whom he entered into a partnership and to whom Woods credited much of his later success. Woods entered politics when he was elected mayor of Newark in 1856. As a prominent leader of the Democrats, Woods was torn between his heartfelt support for the party and his belief in the permanency of the Constitution and Union.
Abandoning the Democratic party for the Republicans, Woods personally acted upon his own rhetoric by volunteering for military service. He saw combat at Fort Donelson, Shiloh, Chickasaw Bayou, Arkansas Post, Jackson and Vicksburg. In 1863 Woods was promoted to colonel and served with such distinction that Generals Ulysses S. Grant, Sherman, and John A. Logan recommended him for promotion to brigadier general in 1865. When mustered out of service in February 1866, he was accorded the brevet rank of major general. In 1869, President Ulysses S. Grant appointed him to the 5th United States Circuit Court of Appeals.
No doubt the most important issue brought to Woods's circuit court was the Slaughterhouse Cases. Decided with Associate Justice Joseph P. Bradley (on circuit), the case tested the issue of the reach and breadth of the 14th Amendment. Bradley and Woods found that a state act that created a monopoly in the slaughterhouse business violated the privilege and immunities clause of the new 14th Amendment and therefore was void. Three years later, a majority of the Supreme Court reversed this circuit court opinion in the Slaughterhouse Cases, with Bradley as one of the dissenters. Early on, Woods was willing to read the provisions of the 14th Amendment broadly. During and after his tenure on the circuit bench, Woods collected, edited, and published four volumes of 5th Circuit Court case reports.
Appointed by President Rutherford B. Hayes to the Supreme Court on Dec. 21, 1880, Woods easily received Senate approval by a vote of 39 to 8; he took the oath of office on Jan. 5, 1881, and began work.
Because Woods did not take a leadership position while on the Supreme Court and because of his conservative principles and his exercise of judicial restraint, Woods has generally received low marks for his short service. Yet from 1881 to 1886, when illness incapacitated him, he wrote 218 opinions, most of which dealt with workaday issues of the court especially in equity law. Once again, the court limited the reach of national power and national citizenship against the states and thereby left blacks vulnerable to white violence in their localities and without federal remedy; all in apparent contradiction of his 5th Circuit Court decision in the Slaughterhouse Cases. But while Woods limited federal power in Harris, he supported federal power in the other case for which he is most remembered. In Presser v. Illinois (1886), he rejected the argument that individuals could carry arms as a federal right in defiance of the policies of a state.
In 1886 Woods was struck with an unspecified illness that prevented him from continuing his duties on the court, though he continued to serve as a member and later died in Washington, D.C. The limited research and sources available on this justice support Chief Justice Morrison Remick Waite's description of him as an upright man and a just judge. Woods influenced the people around him and he responded with concern and dedication to his times and to his constituencies.
