The California Court of Appeal has upheld the state’s decision to rename UC Hastings College of the Law as UC College of the Law, San Francisco, rejecting a lawsuit brought by descendants of founder Serranus Clinton Hastings and a group of alumni who sought to restore the school’s former name.
This ruling marks the latest — and perhaps final — chapter in a years-long legal and public relations battle over the identity of one of California’s oldest law schools. The plaintiffs had argued that the California Legislature’s 2022 law changing the school’s name violated a binding contractual agreement established in 1878, when the institution was founded. The appellate court disagreed, affirming that the Legislature acted within its powers and that no perpetual naming contract had ever existed.
A Controversial Legacy Reexamined
The renaming controversy stems from revelations about Serranus Hastings’ involvement in violent campaigns against Indigenous communities in the mid-19th century. Historical research uncovered that Hastings, who served as California’s first chief justice and a wealthy landowner, helped fund and organize militia expeditions responsible for massacres of the Yuki people in Northern California’s Round and Eden Valleys.
In 2020, a university-appointed committee published findings detailing Hastings’ role in these atrocities. In response, the school’s Board of Directors unanimously voted to pursue a name change in 2021. The decision reflected a broader national movement among universities and public institutions to reckon with historical injustices and remove names honoring figures tied to racism, slavery, or genocide.
By 2022, after months of consultation with lawmakers, alumni, and tribal representatives, the California Legislature passed Assembly Bill 1936, which formally renamed the school UC College of the Law, San Francisco (UC Law SF). Governor Gavin Newsom signed the bill in September 2022, and it took effect on January 1, 2023.
The law not only implemented the new name but also required the university to pursue restorative justice initiatives in partnership with Indigenous communities. These initiatives include collaborating with tribal leaders to develop educational programs, creating memorials or acknowledgments of past violence, and exploring opportunities for future reconciliation.
The Lawsuit Against the State and UC
Following the passage of AB 1936, descendants of Hastings — joined by a handful of alumni — filed suit against the State of California, the University of California’s Board of Regents, and UC Law SF. The plaintiffs contended that the school’s 1878 charter explicitly required it to “forever be known and designated as Hastings College of the Law.”
According to their complaint, this language represented a binding contractual obligation between Serranus Hastings and the state, one that could not be altered by legislative action. They also argued that removing the family’s reserved seat on the school’s governing board violated constitutional protections and undermined the integrity of the University of California system.
In February 2024, San Francisco Superior Court Judge Richard Ulmer dismissed the lawsuit, finding no evidence of a legally binding contract. Judge Ulmer ruled that the 1878 legislation creating the school did not grant Hastings or his descendants perpetual naming rights, nor did it prohibit the state from updating the institution’s name to reflect modern values.
The plaintiffs appealed, maintaining that the lower court erred in dismissing the case. However, the California Court of Appeal recently affirmed the trial court’s decision, effectively ending the case at the state level — though the plaintiffs have indicated plans to petition the California Supreme Court.
Legal Reasoning and Broader Implications
In its decision, the appeals court emphasized that public universities, as state institutions, are subject to legislative authority. The court found that the naming clause in the 1878 statute was descriptive rather than contractual and that the Legislature retains the right to amend or repeal its own enactments.
Legal analysts note that the ruling reinforces the principle that public institutions are not bound indefinitely by historical naming conventions. It may also set a precedent for other universities or agencies seeking to address controversial legacies without fear of breaching contractual obligations with long-deceased benefactors.
“This case demonstrates that evolving societal standards can rightfully inform how we honor historical figures,” said one higher education policy expert. “The court’s decision affirms that the state can act to align public institutions with contemporary moral and ethical values.”
Moving Forward: A Reaffirmed Identity
Since adopting the new name, UC Law San Francisco has continued its rebranding efforts, updating signage, communications, and academic materials. School officials say the focus now is on community healing and forward progress rather than litigation.
Chancellor and Dean David Faigman has described the name change as both an act of accountability and an opportunity for renewal. “This decision allows us to move forward with our mission of training outstanding lawyers who are committed to justice, equity, and inclusion,” Faigman stated in a previous announcement.
The law school’s partnerships with tribal leaders are ongoing, including educational projects that highlight California’s Indigenous history and the Yuki people’s resilience. The institution’s commitment to restorative justice remains a cornerstone of its evolving identity.
While the plaintiffs’ attorneys — including Harmeet Dhillon and Gregory Michael — have expressed disappointment and plan to explore further appeals, the appellate decision represents a significant legal and symbolic victory for UC Law SF and for advocates of institutional accountability.
For now, the university’s modern identity — UC Law San Francisco — stands affirmed by both the law and the courts, signaling a clear path forward for one of the state’s most prominent centers of legal education.
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