Louisiana State Supreme Court Ruling Causes Donor Discontent
The closure of Newcomb College at Tulane University raises question about use of donations.
March 31, 2011 at 08:00 PM
4 minute read
Years after its horrific devastation of New Orleans, Hurricane Katrina just claimed two more victims–Newcomb College for women at Tulane University and the sanctity of donor intent in Louisiana.
The fate of both was sealed in February when the state Supreme Court ruled that Tulane had no obligation to honor Josephine Newcomb's 104-year-old bequest that it maintain, in perpetuity, a women's college as a memorial to her deceased daughter Sophie. After five years of litigation fueled by the spirited opposition of alumnae and Newcomb's descendents, the ruling ratified
Tulane's 2005 decision to abolish the college. The path to the ruling was fraught, both legally and ethically, and revealed the frailty of the rule of law when its officers don't want to comply.
The case began when Tulane cited the damage and effects of Katrina as a reason for restructuring itself, including the elimination of Newcomb College as a separate degree-granting entity. Vociferous opponents of the plan pointed out that the terms of Newcomb's gifts and of her 1901 will required Tulane to keep the college going. Despite the fact that it had honored the very specific conditions Newcomb placed on her gifts for 15 years before she died, and for 104 years after her death, Tulane claimed it had no obligations to her or her descendents.
Three levels of state courts also failed to discover what Josephine Newcomb had in mind when she handed over $70 million (adjusted for inflation) to Tulane University. They seem to have forgotten about the time when Newcomb discovered Tulane wasn't spending her donation on the women's college and threatened to stop funding it and instead establish a new college in Georgia. Tulane quickly apologized and even passed resolutions promising, again, to maintain Newcomb College. The judges probably also didn't think it relevant that Tulane had received other complaints about it not respecting “donor intent.” The judges looked only at the words of her will and concluded that she hadn't placed any restrictions on her bequest, and that Tulane was not required to keep the college going.
But that conclusion ignores both the facts of the case and settled Louisiana law requiring courts to respect both a donor and a testator's intent, and, when that intent is in doubt, to make extra efforts to find out what that intent is. A reading of the key dissent of two appellate judges in the case makes this point as clear as a bell. If I had harbored any doubts– extralegal, emotional, common sensical or otherwise–about the argument to keep Newcomb College intact, they would have been blown away by the clarity and dispositiveness of that dissent. A reasonable person reading the whole record can conclude only that the Powers That Be just wanted to let Tulane have its way.
My cynicism saves me from bafflement about how Louisiana's courts could ignore their own law. I am guided in my thinking by the words of others, such as Machiavelli (or, more recently, the new Chicago mayor, Rahm Emanuel) who said, “Never waste a good crisis,” as Tulane certainly did not when Katrina became the excuse to take over Newcomb's legacy. Or that disreputable fixer Roy M. Cohn who said, “I don't want to know what the law is; I want to know who the judge is,” and whose sentiment might have inspired Tulane's confidence in the state's judiciary to reach the desired decision. And every first-year law student recalls the contracts professor who said about nearly every issue, “That is the majority rule of law in the United States–except in Louisiana.” Now we can add, “The majority rule is that 'donor intent' must be given great deference–except in Louisiana.”
As former Newcomb College Dean, Anna E. Many once said, “Remember ladies: [Tulane] only married us for our money.”
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllLawyers Drowning in Cases Are Embracing AI Fastest—and Say It's Yielding Better Outcomes for Clients
GC Conference Takeaways: Picking AI Vendors 'a Bit of a Crap Shoot,' Beware of Internal Investigation 'Scope Creep'
8 minute readWhy ACLU's New Legal Director Says It's a 'Good Time to Take the Reins'
Trending Stories
- 1Call for Nominations: Elite Trial Lawyers 2025
- 2Senate Judiciary Dems Release Report on Supreme Court Ethics
- 3Senate Confirms Last 2 of Biden's California Judicial Nominees
- 4Morrison & Foerster Doles Out Year-End and Special Bonuses, Raises Base Compensation for Associates
- 5Tom Girardi to Surrender to Federal Authorities on Jan. 7
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250