Naming Public Schools and the First Amendment
The naming and renaming of public spaces, buildings and schools has historically involved an uneasy balance of legal, political and community goals and heightened emotions.
On September 9, 2025, District Judge Michael F. Urbanski issued a 71-page opinion holding that the Shenandoah County, Virginia school board’s decision to reinstate the name “Stonewall Jackson High School” made students “mobile billboards” for the restored Confederate name in violation of the students’ constitutional rights. Virginia State Conference NAACP v. County School Board of Shenandoah County, 5:24-cv-00040, (W.D. Va. Sep 09, 2025) ECF No. 171. Specifically, the school board’s decision forced individuals to “to serve as “instrument[s] for fostering public adherence to an ideological point of view [they] find unacceptable.” Id. at 21, quoting Wooley v. Maynard, 430 U.S. 705, 715 (1977).
This case and similar cases will likely be debated in the courts and media for some time to come. If you are interested in more background on naming issues, see Lutzker & Lutzker’s articles:
Hail to the… Washington Football Team? (July 27, 2020)
What’s in a Rename: Changing School, Building and Program Names Within Educational Institutions (September 14, 2020)
What’s in a Rename: Public Spaces (December 22, 2020)
Museums and Questions of Donor Morality: The Sackler Case (July 12, 2022)
Columbus Day or Indigenous Peoples’ Day? (September 27, 2022)
Native American Mascoting in K-12 Schools (July 21, 2023)