Woods, William Burnham
(b. Newark, Ohio, 3 August 1824; d. Washington, D.C., 14 May 1887; interred Cedar Hill Cemetery, Newark), associate justice, 1881–1887. Appointed to the Court by President Rutherford B. Hayes in 1880, Justice William B. Woods served until his death in 1887. During his brief tenure, Woods was part of the Court’s mainstream that gave a narrow reading to the Civil War Amendments, particularly the *Fourteenth. His most important opinions restricted congressional ability to protect individuals from private infringement of civil rights and rejected the applicability of the *Bill of Rights to the states.
William B. Woods was the son of Ezekiel S. Woods, a farmer and merchant, and Sarah Burnham. He graduated from Yale College and clerked with S. D. King, an Ohio attorney; in 1847 he was admitted to Ohio’s bar. Active in the state’s Democratic party before the Civil War, he served in the state legislature on the eve of the conflict. During the war he served in an Ohio volunteer regiment and rose to the rank of brevet major general.
After the war, Woods settled in Alabama and switched his political allegiances to the Republican party. He served in that state’s chancery court system, developing an expertise in equity, for which he would later be noted in the federal courts. In 1869 President Ulysses S. Grant appointed him to the Fifth Circuit Court, where he initially took a more expansive view of the guarantees provided by the Fourteenth Amendment than he would later on the Supreme Court. While on the(p. 1098)
Fifth Circuit he voted to strike down government mandated monopoly as violative of the Fourteenth Amendment’s Privileges or Immunities Clause. He also interpreted that clause as allowing the federal government to punish private violations of civil rights.
After his appointment to the Supreme Court in 1881, Woods’ view of the Fourteenth Amendment grew more conservative. He joined with the majority in the *Civil Rights Cases to strike down the Civil Rights Act of 1875 as exceeding federal power.
His two most significant opinions involved the Fourteenth Amendment. In United States v. Harris (1883), he struck down the Ku Klux Klan Act of 1871 on the grounds that protection of individuals from private conspiracies was a state not a federal function. In another opinion, *Presser v. Illinois (1886), Woods limited the possibilities of applying the Bill of Rights to the states through the Fourteenth Amendment. In Presser, which involved an Illinois statute that prohibited private citizens from parading while armed, Woods held that the *Second Amendment limited federal but not state action.
Justice Woods’ jurisprudence reflected a concern with maintaining state prerogative and limiting federal power. That concern played a significant role in helping to limit the ability of the Fourteenth Amendment to act as a vehicle to protect individual rights.
L. Filler, “William B. Woods,” in The Justices of the Supreme Court of the United States, 1789–1969, edited by Leon M. Friedman and Fred L. Israel, vol. 2 (1969), pp. 1327–1336.
Robert J. Cottrol