were not many instances, however, in which Woods found it necessary to raise an individual voice. For the most part he sought moderation and consensus, and was content to follow others who more actively chose to formulate social goals and controls.
Such qualities did not suffice to bring him distinction. Although his voice was the voice of the majority—not only of the Court but of the larger public—he failed to express its more complex feelings. He reflected their mundane compromises, but not their ideals or their more creative hopes. They, in turn, perceived of him as nothing more than a southern judge. His death on May 14, 1887, though he was affectionately memorialized by his colleagues, roused no public recollections, even of his military career. The New York Times in its space allotted to him concentrated almost entirely on conjectures about who might succeed him on the bench, with intimations that it might be another southerner who would fill the place he had vacated. (The post in fact went to L.Q.C. Lamar of Mississippi.) Even his own Cincinnati Enquirer, though it termed him an eminent soldier and jurist, devoted most of his obituary to debate the question of his successor.
As is appropriate to one whose career has been largely ignored and misconstrued, bibliographical material on Justice Woods is meager in the extreme. His best memorial is his own series of reports, Cases Argued and Determined in the Circuit Courts of the United States for the Fifth Judicial Circuit, issued in Chicago between 1875 and 1883, which gives the range of the cases in which he participated and reveals his outlook and qualities. E. M. P. Brister II , Centennial History of the City of Newark and Licking County, Ohio ( 1909), tells something of his background; Whitelaw Reid's Ohio in the War ... ( New York, 1868), something of his war services. More recently, T. B. Baynes produced an article in Supreme Court Historical Society Yearbook 1978 ( Washington, D.C., 1978) fittingly entitled " A Search for Justice Woods: Yankee from Georgia." See also Joseph P. Smith, ed., History of the Republican Party in Ohio ( Chicago, 1898), Proceedings of the Bench and Bar of the Supreme Court of the United States in Memoriam William B. Woods, 123 U. S. 761 ( 1887), and 15 Washington Law Reporter 357 ( 1887).