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Trending: Nonprofits Tossing Out Unsavory Names

06.14.23 | Linda J. Rosenthal, JD

“Renaming or ‘denaming’ has become a way for cities and institutions to denounce or reckon with contentious figures of the past,” reporter Rachel Swan of the San Francisco Chronicle explained recently.

Several weeks ago, Ms. Swan told her readers about the tricky dilemma facing the University of California, Berkeley – right now – after “more than a century and a half cementing the reputation of its [stellar] brand.”

UC Berkeley “… ranks among the best public and private universities, known globally for its list of Nobel laureates and inventions, as well as its tradition of political activism” in a world-famous urban center. But much of this valuable name recognition and enviable goodwill could evaporate if the name “Berkeley” becomes too toxic for the university – (and the entire town!) – to retain. See Rename UC Berkeley? How the university is responding to ‘denamed’ overseas library (May 9, 2023).

“Denaming” Trend

In the past several years, particularly against the background of diversity and equity movements like Black Lives Matter, there has been an explosion of cases in which stakeholders and citizens have objected to the names of nonprofit institutions and their component buildings and other parts.

There is controversy slowly bubbling up over certain aspects of the life and beliefs of George Berkeley, Bishop of Cloyne, an 18th-century Irish cleric. He was a world-renowned and influential philosopher and poet, considered one of the leading thinkers of his era. One of his most famous poems is Prospect of Planting Arts and Learning in America, including the phrase: “Westward the Course of Empire Take Its Way.” But, during a period when he lived in Rhode Island, he was a slave owner. He also espoused beliefs that, to modern sensibilities, are offensive and extreme. For instance, he had a plan (not carried out) to kidnap Native children and force them to convert to Christianity.

Among George Berkeley’s (future) admirers were the founding trustees of the proposed first land-grant university in California. They were having trouble settling on an appropriate name for the college and the adjacent town to be built.  On a balmy afternoon in May 1866, as the men visited the breathtaking Pacific-coast site of the future first campus of the UC system, one of the trustees recalled Berkeley’s inspirational words about “… westward the course of empire….” in the context of “planting arts and learning in America.” He reminded the others of it. They were so moved that – voila – they chose “Berkeley” as the name for their exciting new project.

It’s not that the current people of Berkeley (university and town) have been unaware of the particulars of George Berkeley’s life and works. But little attention was paid to it until recently. In an opinion piece published last year, a longtime Berkeley resident advocated for renaming the city: “It’s time for us to move on from the past. The city of Berkeley, our city, is named after a slave owner, racist, and colonialist.”

The Chronicle’s Rachel Swan adds: “The quandary facing UC Berkeley extends to the city at large, where discussions of a name change are already percolating, but not gaining much traction.” The Mayor of Berkeley “declined to comment.”

Nevertheless, the matter of the unsuitability of honoring George Berkeley in such a progressive bastion has not gone entirely unnoticed, and momentum may soon grow.

Boalt Hall was “Unnamed” 

It’s important to note that there has, indeed, been some chipping away in the Berkeley area of unfortunate or unsavory names. For instance, in 2020, the Regents of the University of California approved a broadly supported proposal to “dename” the key building of the law school there, tossing out “Boalt Hall” for good. See Chancellor Carol Christ: Why we denamed Boalt Hall (January 30, 2020) “This is the first time a UC Berkeley building has had its name removed because the values of its namesake were so out of sync with those of our institution.”

“In 2017,” Chancellor Christ elaborated, “it came to light that Boalt Hall’s namesake — John Henry Boalt — was a leading figure in the movement to ban those of Chinese ancestry from the United States in the 19th and early 20th centuries. Boalt made profoundly offensive and racist statements about Chinese and Chinese Americans, suggesting that it would be better to ‘exterminate’ those of Chinese descent than to have them assimilate.”

The denaming decision was made easier since there was no connection at all of Mr. Boalt either to the law or to UC other than a $100,000 gift in 1901 from his widow to build a “Boalt Memorial Hall of Law.” See UC Berkeley removes racist John Boalt’s name from law school (January 30, 2020) Gretchen Kell, Medial relations,

A Development Overseas

Meanwhile, half a world away, at Trinity College Dublin (TCD), there has been considerable consternation over Bishop Berkeley’s unsavory beliefs and activities.

But – in stark contrast to the relative inertia in California – the Irish have taken dramatic action.  In fairly short order, they accomplished the “denaming” of TCD’s (modern-day) main library building. There is no longer a “Berkeley Library” at Ireland’s oldest and highest ranking university founded by England’s Queen Elizabeth I in 1592.

This step was popular across the broad range of stakeholders despite there being a much more direct connection with George Berkeley. He had been a student at Trinity College Dublin in the early 1700’s as well as a faculty member and a librarian there. See What does the ‘denaming’ of Trinity’s Berkeley Library mean? (April 29, 2023) Carl O’Brien, The Irish Times [“University decided this week that use of the philosopher’s name – which has been linked to slavery – was inconsistent with its core values”]. See also A Philosopher and a Slaver, but No Longer a Name on a Library (May 8, 2023) Ed O’Loughlin, The New York Times.


There’s much more to say about this intriguing topic: that is, the recent rash of “denamings” and “unnamings” at our charitable institutions.

For instance, it all gets particularly dicey when there’s money involved; namely, when an institution, or a part of it like a building or a wing or an endowed chair, takes on a donor’s name in consideration of a hefty donation. There are current cases of interest, which we’ll discuss. See for example: Former ‘Hastings’ law school loses appeal to block suit over name change (June 6, 2023) Karen Sloan, and Middlebury Sued Over Changing Name of Chapel (March 26, 2023) Scott Jaschik,

There is also a growing body of guidance, particularly from the major higher educational institutions, that can help not only big urban institutions but also smaller and more local ones navigate the tricky issues in the decisions to toss (or not) unsavory or unfortunate names.

– Linda J. Rosenthal, J.D., FPLG Information & Research Director


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