In a June 5, 2026 decision, the Iowa Supreme Court held that the University of Iowa cannot unilaterally change a privately funded scholarship designated for Black students in chemistry to a race-neutral “first-generation” program. The ruling in In re Ezra L. Totton Scholarship stresses the importance of donor intent while acknowledging legal pressures from the 2023 U.S. Supreme Court affirmative action decision (Students for Fair Admissions v. Harvard).

Background

Dr. Ezra L. Totton, a Black chemist and civil rights pioneer who earned his doctorate from the University of Iowa in 1945, established the scholarship in his will. The fund, grown from an initial $35,000 bequest to about $58,000, was explicitly created to support Black students pursuing physical sciences, especially chemistry. Totton’s gift reflected his own experiences overcoming racial barriers in education, including early lawsuits against segregated graduate programs.

After the 2023 ruling banned race-based admissions at universities receiving federal funds, the University of Iowa sought court approval to modify the scholarship. Citing legal risks, it proposed redirecting aid to first-generation college students instead of Black students. A lower court initially rejected the change, leading to the appeal.

The Court’s Ruling

The Iowa Supreme Court agreed the original race-specific restriction had become impracticable under current law. However, it ruled the university’s proposed modification did not sufficiently honor Dr. Totton’s intent. Key points:

•  Private donor funds in charitable trusts receive strong protection for the donor’s original purpose.

•  Courts, not the university alone, must oversee significant changes via the cy près doctrine (“as near as possible”).

•  The case is remanded to district court for further proceedings, including input from donor advocates and the Totton family, and exploration of alternatives such as narrowed criteria, fund transfer, or other compliant solutions.

Stakeholder Views and Implications

Civil rights groups, including the ACLU of Iowa and NAACP, supported preserving the scholarship’s focus on Black students, citing persistent disparities in STEM enrollment and financial need. Family members emphasized Totton’s clear desire to aid African American students specifically.

The decision highlights broader national challenges: public universities managing race-restricted private endowments post-2023. It reinforces donor autonomy but requires institutions to seek judicial approval for modifications rather than acting independently. Race-neutral proxies (e.g., socioeconomic status) are common workarounds, though their effectiveness varies.

This ruling provides a balanced framework—respecting philanthropy rooted in historical context while navigating equal protection requirements. The district court’s next steps could set precedents for similar scholarships nationwide. The case remains ongoing, with potential for further appeals or creative resolutions.

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