A California state appeals court has ruled that the state acted lawfully when it removed Serranus Clinton Hastings’ name from the University of California College of the Law, San Francisco, rejecting claims by Hastings’ descendants and alumni that the change violated a binding contract and constitutional protections.
In a unanimous opinion authored by Justice Jeremy M. Goldman and issued Wednesday, the First Appellate District Court of Appeal upheld a lower court’s decision to dismiss the lawsuit, concluding that California’s legislature retained the sovereign authority to rename and restructure a public institution—even one established by statute in the 19th century.
Court Rejects Contract and Constitutional Claims
The plaintiffs had argued that an 1878 legislative act, which declared the school “be forever known and designated as ‘Hastings’ College of the Law,” constituted a binding contract between the state and S.C. Hastings, California’s first chief justice and a major benefactor of the law school. However, the court rejected that theory, emphasizing that the naming provision was a statutory designation, not a contractual promise.
“The appellation of a public institution or agency, or the qualifications of individuals entitled to manage it, are matters of public significance,” Justice Goldman wrote. “Future changes may be deemed important to advance the institution’s obligation to serve the public interest.”
The court held that California cannot “contract away” its authority to manage its own public institutions and found no violation of either the state or federal Contracts Clause.
No Punishment or Personal Blame Imposed
The decision also rejected the plaintiffs’ claims that Assembly Bill 1936—which officially renamed the school UC College of the Law, San Francisco, effective January 1, 2023—functioned as an unconstitutional bill of attainder. The justices determined that the law neither imposed punishment nor deprived the Hastings family of property or vested rights.
“The bill imputes no blame to any of S.C. Hastings’s descendants for his conduct,” the court said. “It does not directly or implicitly impugn their character.”
A.B. 1936 also eliminated the hereditary board seat held by Hastings’ descendants since the school’s founding, a symbolic change that the court likewise deemed constitutional.
Historical Context and Legislative Motivation
S.C. Hastings, California’s first chief justice and third attorney general, was one of the state’s wealthiest landowners by 1870. The name change came after the law school commissioned an independent report linking Hastings to the mid-19th-century massacres of Yuki Indigenous people in Northern California. The findings showed that Hastings had funded and organized efforts to expel Native Americans from land he had purchased in Mendocino County—actions that led to the deaths of hundreds.
The plaintiffs, including Hastings’ descendants and several alumni, filed suit in 2022, arguing that the killings were carried out by a state militia beyond Hastings’ control and that the legislature’s renaming act was politically motivated. The appeals court, however, agreed with the state’s position that the school’s own governing board supported and requested the changes, undercutting claims of improper political influence.
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