SCOTUS: UC Hastings Law Name Change Stands After Review Denial

• The U.S. Supreme Court recently allowed the University of California College of the Law at San Francisco to retain its new name.
• The name change followed revelations that original namesake Serranus C. Hastings ordered the slaughter of Native Americans in the 1860s.
• Descendants of Hastings and alumni sued, claiming the original 1878 naming law was a binding contract and sought $1.7 million.
• California courts ruled the 1878 law was a repealable legislative act, not a contract.
• The Supreme Court denied review of the case in a one-sentence order, affirming the state's power to change the name.

This ruling underscores that state legislatures generally retain the power to repeal or amend prior legislative acts, even those framed as 'contracts,' especially when public policy considerations are at play.

The U.S. Supreme Court recently declined to hear a challenge regarding the renaming of a prominent California law school, effectively allowing the institution to permanently adopt its new designation as the University of California College of the Law at San Francisco. This decision marks the culmination of a significant dispute over the school's historical ties to its original namesake, Serranus C. Hastings, whose past actions involving Native American communities came under scrutiny. The high court's one-sentence order, issued without any indication of dissenting justices, solidifies the state's authority to alter the name despite objections from Hastings' descendants and some alumni.

The controversy stems from revelations that Serranus C. Hastings, a former Chief Justice of the California Supreme Court and state attorney general, ordered the slaughter of thousands of Native Americans in the 1860s. Although Hastings was also a rancher who blamed tribes for attacks on his cattle, evidence emerged in the last decade confirming his role in sending militia against Native Americans in Mendocino County, California. This historical context prompted the California legislature to pass a law, effective in 2023, which changed the institution's name from the University of California Hastings College of the Law to its current form, sparking the legal challenge that ultimately reached the nation's highest court.

The legal challenge to the name change was initiated by six descendants of Serranus C. Hastings, alongside several alumni, who filed a lawsuit against the state. Their central argument posited that the original 1878 state law establishing the school constituted a binding contract, which explicitly stated the institution "shall forever be known as" the University of California Hastings College of the Law in San Francisco. As part of this foundational agreement, Hastings had committed $100,000 to establish the school, and the plaintiffs sought the return of this sum, plus interest, totaling $1.7 million, alleging a breach of this historical contract.

However, California's judicial system consistently rejected this contractual interpretation. Lower state courts ruled that the 1878 enactment was not a perpetual contract but rather a legislative act subject to repeal. This determination was subsequently affirmed by a state appeals court, setting the stage for the final appeal to the U.S. Supreme Court. The SCOTUS denial of review effectively endorsed the California courts' interpretation, confirming the state's power to amend or repeal its own legislative acts, even those with historical financial commitments.

The Supreme Court's decision to not intervene in the Hastings College of the Law name dispute carries significant implications for the scope of legislative authority, particularly concerning historical enactments. This ruling underscores that state legislatures generally retain the power to repeal or amend prior legislative acts, even those framed as 'contracts,' especially when public policy considerations are at play. It reinforces the principle that legislative bodies can re-evaluate and modify past decisions in light of evolving societal values and historical understanding, even if those decisions involve foundational agreements.

This outcome suggests that historical legislative enactments may not be immune to future legislative changes, particularly if they are not explicitly and robustly protected as contractual obligations. For legal professionals, this case serves as a reminder that the permanence of legislative acts, even those seemingly enshrined with terms like "forever," can be challenged and altered by subsequent legislative action. The University of California College of the Law at San Francisco, which boasts notable alumni such as Vice President Kamala Harris and former San Francisco Mayor Willie Brown, can now move forward with its new identity, free from the legal shadow of its controversial namesake.

This ruling confirms that state legislatures generally retain the power to repeal or amend prior legislative acts, even those framed as 'contracts,' particularly when public policy considerations are at play. Lawyers should advise clients that historical legislative enactments may not be immune to future legislative changes, especially if they are not explicitly and robustly protected as contractual obligations.

Source: Original reporting via ABAJournal.com