William Burnham Woods (August 3, 1824 – May 14, 1887) was an American jurist who served as an associate justice of the Supreme Court of the United States.
He joined the Union army as an officer, participating in a number of battles; after his discharge as a brevet major general in 1866, he settled in Alabama, where he practiced law and engaged in commercial activities.
In the Slaughter-House Cases and United States v. Cruikshank, he favored a broad interpretation of the Fourteenth Amendment that contrasted with the narrower one he supported on the Supreme Court.
[7]: 10, 12 Little information is available as to why the President selected Woods, but Thomas E. Baynes Jr. suggests that his Republican politics, his military service with Grant, and the fact that his brother-in-law Willard Warner was a U.S.
[7]: 13 In another privileges-and-immunities decision, United States v. Hall (1871), Woods sustained an indictment under the Enforcement Act of 1870, holding that the Fourteenth Amendment gave Congress the power to protect the freedoms of speech and of assembly through legislation.
[2]: 1330 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.
[2]: 1331 Ohio notables and Southern congressmen recommended Woods for an 1877 vacancy on the U.S. Supreme Court, but President Rutherford B. Hayes nominated John Marshall Harlan instead.
[2]: 1333 [5]: 35 Additionally, Woods's connections to both North and South made him "precisely the kind of candidate Hayes sought to help bind bitter sectional wounds", according to the legal scholar Henry J.
[5]: 35 Despite concerns that too many justices from Ohio were being appointed (Chase, Waite, Swayne, Woods, and the rumored next nominee Stanley Matthews were all associated with that state), the Senate confirmed him by a vote of 39 to 8[5]: 35–36 on December 21, 1880.
[1]: 225 Most of his opinions for the Court were in uncontroversial cases, often involving real property, patents, taxation, commerce, municipal law, trusts, or corporations.
[1]: 225 The decision, which involved defendants charged with breaking into a jail and beating four black prisoners (in one case to death), held that the Ku Klux Klan Act exceeded Congress's power.
[16]: 142 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;[12]: 619 it "limited the possibilities of applying the Bill of Rights to the states through the Fourteenth Amendment", according to the legal scholar Robert J.
[15]: 55 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".
[12]: 619 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".