William Burnham Woods

William Burnham Woods was born in Newark, Ohio, on August 3, 1824, to Ezekiel S. Woods, a Kentucky-born merchant and farmer, and Sarah Burnham Woods, who was from New England. He attended Western Reserve College (now Case Western Reserve University) before transferring to Yale University, from which he graduated as valedictorian in 1845. After returning to Newark, he studied law under the tutelage of S. D. King, a prominent lawyer; the two became partners after Woods was admitted to the bar in 1847. While some evidence suggests that he was at first a Whig, he later became a member of the Democratic Party. At first Woods staunchly opposed the policies of the Lincoln administration, but when the Civil War broke out, he supported the Union cause, vowing to stand by the federal government "in sunshine or storm, in peace or war, right or wrong". In February 1862, he joined the 76th Ohio Infantry Regiment as a lieutenant colonel, becoming colonel in September when the previous colonel – his brother, Charles R. Woods – was promoted to brigadier general. and participated in the Grand Review of the Armies in Washington. Just before his discharge in February 1866, he was brevetted a major general at the recommendation of Generals Sherman, Ulysses S. Grant, and John A. Logan. After being mustered out, Woods settled in Alabama, where he had been serving; there he practiced law, involved himself in cotton production, and invested in ironworks. He had by this time become a Republican, and in 1868 he was elected on the Republican ticket chancellor of the middle chancery division of Alabama. == Circuit judge ==

When an 1869 judicial reorganization law created nine new circuit judgeships, In Bertonneau v. Board of Directors of City Schools, an 1878 school segregation decision, Woods offered an early formulation of what became the separate-but-equal doctrine. He argued that while states were obliged to afford "equal privileges and advantages to both races", they could otherwise manage schools in whatever way they thought best. For Woods, the substance of the case was that "[w]hite children and colored children are compelled to attend different schools. That is all." In its notorious 1896 decision in Plessy v. Ferguson endorsing the separate-but-equal doctrine, the Supreme Court cited Bertonneau and other similar decisions that had upheld racial segregation in public schools. Woods expended considerable effort to learn Louisiana law, which was especially complicated due to its French and Spanish roots. He prepared four volumes of reports of cases decided by the circuit court. In the aftermath of the contested 1876 presidential election, he avoided becoming involved in a dispute over the eligibility of a Florida Republican elector who had attempted to resign another federal office by writing to Woods. Woods moved to Atlanta, Georgia, in 1877. == Supreme Court nomination ==

When a U.S. Supreme Court vacancy arose in 1877, many political figures urged President Rutherford B. Hayes to nominate Woods. Hayes, however, nominated John Marshall Harlan instead. == Supreme Court service ==

Woods remained on the Supreme Court until his death in 1887. His jurisprudence was generally nationalistic: he joined the majority in Juilliard v. Greenman to hold that the federal government could lawfully print paper money, and he dissented when the Court held in United States v. Lee that individuals could sue federal officers. He wrote for an eight-justice majority in United States v. Harris (1883) that the Fourteenth Amendment did not authorize laws that prohibit individuals from interfering with other individuals' civil rights. in which Woods joined the majority in holding much of the Civil Rights Act of 1875 unconstitutional. In Presser v. Illinois, involving a man convicted of violating Illinois law by carrying firearms as part of a private militia, Woods's opinion for a unanimous Court held that the Second Amendment applied only to the federal government; His condition seemed to be improving during a lengthy stay in California, but it soon worsened. President Grover Cleveland nominated Lucius Quintus Cincinnatus Lamar to replace him. ==Legacy==

The scholar Louis Filler began a 1969 essay on Woods by describing him as "one of the least known of all the Justices who have served on the United States Supreme Court". A 1970 survey of law professors rated him "below average", but the legal scholar D. Grier Stephenson suggests that this rating "probably results more from general unfamiliarity than from a careful appraisal of his work". The historian Stephen Cresswell attributes Woods's low historical reputation to his brief tenure, the frequency of his votes with the majority, and perceptions that he was a carpetbagger with a "muddled judicial philosophy". According to Timothy L. Hall, "[m]ore a follower than a leader, more an echo of the reverberating ideas of others than an original thinker in his own right, his brief years on the Court climaxed a life too far removed from the center of events to warrant more than passing historical mention". ==See also==