“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.