Tennessee Division of the United Daughters of the Confederacy v. Vanderbilt University
Court of Appeals of Tennessee
174 S.W.3d 98 (2005)
The Tennessee Division of the United Daughters of the Confederacy (TUDC) (plaintiff) donated $50,000 to Peabody College across three agreements between 1913 and 1933 to build a dormitory named "Confederate Memorial Hall," where female descendants of Confederate soldiers nominated by TUDC could live rent-free. Vanderbilt University (defendant) assumed Peabody's obligations in a 1979 merger and later ended the residency program; after renovating the building and facing recurring controversy over its name, a new chancellor moved to remove "Confederate" from the building, and Vanderbilt had done so everywhere except the building's stone pediment when TUDC sued for breach of contract in 2002. The trial court found Vanderbilt had substantially performed its obligations and granted summary judgment permitting the name change.
Whether a university that accepted a conditional charitable gift requiring a building to bear a specific name may remove that name without either honoring the condition or returning the gift.