L.B. Research & Education Foundation v. UCLA Foundation

A donor contributed $1 million to establish an endowed chair at the UCLA School of Medicine, which UCLA accepted along with the conditions imposed by the donor. The primary question on this appeal is whether the agreement created (1) a contract subject to a condition subsequent or (2) a charitable trust, the answer to which supposedly determines whether the donor has standing to sue UCLA and the Regents of the University of California to enforce the terms of the gift. We find there is a contract subject to a condition subsequent, not a charitable trust, and also find that, in either event, the donor has standing to pursue this action. Because the trial court reached a contrary result, we reverse.

FACTS

A.

In July 2000, the L.B. Research and Education Foundation (a nonprofit public benefit corporation) gave the UCLA Foundation (a fully qualified public charity) a contribution of $1 million to establish an endowed chair, the Julien I. E. Hoffman, M.D., Chair in Cardiothoracic Surgery. By the terms of the parties’ agreement (which was signed by both L.B. Research and the UCLA Foundation), the fund thereby created must be used by Chair holders who meet specified criteria…