A federal judge ruled this month that Shenandoah County must remove the names of Confederate generals from two of its schools, names the school board had removed in 2020 and re-added in 2024.
Judge Michael Urbanski ruled that resurrecting the names discriminated against Black students and violated federal civil rights laws. The school board last week voted to appeal the case. But even if the ruling stands, legal experts say it has limited value as precedent to require name changes for other schools named after Confederate figures.
The names of Stonewall Jackson, J.E.B. Stuart and Robert E. Lee could once be found on schools around the commonwealth. From Hampton to Petersburg, most school divisions have renamed them.
More than 20 remained as of 2018; several were changed that year, and many of the remainders were changed in 2020 as a result of Black Lives Matter advocacy and protests. The Campus at Lee became Hampton City Schools Adult and Alternative Center in late 2017; Jefferson Davis Middle in Hampton became Cesar Tarrant in 2018, named for an enslaved naval pilot whom the General Assembly granted freedom following his service in the American Revolution.
Just a handful remain in 2026, including York County's Magruder Elementary School. It shares the name of Brig. Gen. John Magruder, who commanded the Army of the Peninsula for the Confederacy. Magruder is known for ordering Hampton to be burned down in 1861 after reading about Fort Monroe commander Maj. Gen. Benjamin Butler’s plan to settle escaped enslaved people there.
The local NAACP and other community groups have, in recent years, called for York County's Magruder to be renamed. The York County School Board in 2025, however, voted against it.
The school division argued the school is named for the former Magruder village, a historically Black community that was displaced during the creation of Camp Peary; though the division acknowledges the village was likely named after Magruder.
Li Reed is a lawyer with Covington & Burling, one of three firms that represented the Virginia NAACP and families that sued Shenandoah County. She said the situation in Shenandoah is unique.
The Shenandoah board voted to change the names of Stonewall Jackson High and Ashby-Lee Elementary to Mountain View High and Honey Run Elementary six years ago. In doing so, Reed said, the school board made clear they made the change at the time because of the names’ discriminatory impact on students.
“I think that creates a very difficult hurdle for the school board four years later to say ‘we’re going to put the names back and they’ll have no impact,” she said. “The names could be harmful to Black students, could make Black students and other minority students feel unwelcome, and those are some of the key reasons why the school board in 2020 decided to remove the names.”
The school board changed the names back in 2024 after a conservative shift in its makeup following the 2023 election. Board members who supported reinstating the names of Jackson, Robert E. Lee and cavalry officer Turner Ashby, said that the board ignored popular sentiment when it renamed the schools in 2020.
That sets Shenandoah County apart from localities that may have schools with Confederate namesakes, but haven’t explicitly acknowledged that the names may harm students of color.
“I’m not sure that I’m aware of any case with facts similar to this case that would mean that the implications of this case would impact that school,” Reed said. “Every school is going to have a different factual record and the success or failure of the case would likely turn on that factual record.”
Vivian Hamilton, a law professor at William & Mary, feels similarly.
“This is not your typical case where the schools had a long-standing name, where the name would have been left in place by inertia and the path of least resistance,” Hamilton said. “I doubt that we would see these facts replicated.”
Urbanski’s ruling doesn’t give a mandate for schools outside of Shenandoah to change. Hamilton said that makes it less useful as a precedent, but not completely useless.
“There was a lot of evidence presented that went to demonstrating the discriminatory effect on Black students of retaining names like this, and it’s possible that those findings might be used to buttress a later case,” she said. “Future plaintiffs could take a page from this litigation playbook.”
But whether the outcome is the same would depend on the facts of the case and the board’s legislative record, Hamilton said.
“The plaintiffs would still have the burden of demonstrating that the name is racially discriminatory, adopted for racially discriminatory reasons and that certain students are disproportionately adversely affected by the retention of the name.”
Matthew Fontaine Maury High and W.H. Taylor Elementary schools in Norfolk also bear the names of Confederate officers from Virginia. Norfolk’s school board in 2020 came to a consensus to rename them; progress, however, halted as the division began plans to replace Maury and consolidate many of its buildings by 2034 because of declining enrollment.
Norfolk Public Schools and the York County School Division are members of HRETA, which owns WHRO’s broadcast license.
