A federal judge has ruled that Shenandoah County must remove the names of three Confederate generals from its schools.
This is a decision that is likely to be as misunderstood as it is controversial.
I cannot alleviate the controversy inherent in this ruling, but I will attempt to make it easy to understand (so if you’re still outraged, you’re at least outraged based on the facts and not some blurb you saw on social media).
The key thing to understand here is that U.S. District Judge Michael Urbanski specifically says that his ruling does not apply to Confederate-named schools elsewhere, that this decision rests on unique factors in Shenandoah County that aren’t present elsewhere. That means Turner Ashby High School in Rockingham County is safe even though Ashby-Lee Elementary in Shenandoah County must now find another name (although it’s possible someone could challenge the Turner Ashby name and cite this ruling, saying the logical conclusion of this ruling is that it ought to extend there).
Let’s look at those unique factors, which Urbanski writes compelled him to make his ruling in favor of the Virginia NAACP and four students (some now former students) who had gone to court to force a name change. Whether you agree with his decision or not, his 141-page ruling constitutes a powerful history lesson about what remains a consequential but misunderstood period of Virginia history — the “massive resistance” of the 1950s and early 1960s against school desegregation. (The full opinion is embedded at the end of this column.)
Shenandoah County’s history, as it relates to these school names, does not begin uniquely at all. In 1957, the county began building three new high schools, which opened in 1959. These were the peak years of Massive Resistance, which saw a revival of Confederate iconography across Virginia and the South at large. When it came time to name the schools, the county gave two of the three schools geographic names. The northernmost one was named after the town — Strasburg High School. The middle one, in Woodstock, was named Central High School because it was located in the center of the county. The southernmost one, at Mt. Jackson, was named after a person — the Confederate General Stonewall Jackson, whose name edged out the alternative choice of Robert E. Lee. (The similiarity between Stonewall Jackson and Mt. Jackson is coincidental; the town was named after Andrew Jackson for his actions during the War of 1812; it’s that Jackson who appears on the town seal and town flag, not the Confederate general.)
Why did that one high school get named after a person? At the time, Shenandoah County had no high school for Black students; any Black students who wanted to attend high school were bused out of the county, typically to Harrisonburg. Even after the U.S. Supreme Court’s ruling in Brown v. Board of Education, Shenandoah County persisted in sending its Black students out of the county. The coming end of segregation threatened this arrangement. Brian Daugherity, a history professor at Virginia Commonwealth University, studied the minutes of Shenandoah County School Board meetings during that era and testified that “the naming of Stonewall Jackson High School was undertaken by the Shenandoah County School Board, in part, to dissuade [Black] students from requesting transfers into the newly constructed and newly opened high school.”
A Confederate battle flag flew over the school during its construction. Not until 1963, four years after the school’s opening, and nine years after the Brown decision, were Black students finally admitted to Shenandoah County schools.
A new elementary school nearby didn’t open until 1974; when it did, the name Ashby-Lee was chosen. Urbanski wrote in his opinion that Daugherity testified that naming decision was “made in part to discourage Black families from attending these schools and that the selected school names function as vestiges of the formerly segregated, dual school system.”
Fast forward to 2020, the death of George Floyd in Minneapolis and the national reckoning with racial matters that followed. In the aftermath of that, the Shenandoah County School Board voted 5-1 to retire the names Stonewall Jackson and Ashby-Lee. The schools were renamed Mountain View and Honey Run.
That decision proved to be an unpopular one in the county. New elections brought in a new school board, on a platform of restoring the old names. In May 2024, the school voted voted 5-1 to restore the old Confederate names. That set the stage for the lawsuit that followed — and Urbanski’s ruling.
The trial in the case produced arguments on the role of democracy (based on the school board elections, popular opinion in Shenandoah County seems to be on the side of the Confederate names) and the psychological impact of Confederate imagery on Black students. Much of Urbanski’s ruling deals with the history of how the original naming of Stonewall Jackson High School seems inextricably linked to Massive Resistance. This was not some historical school name that previously existed in the county; its naming was a deliberate choice at a time when the county was trying to make it clear that it supported segregation and thought the best way to send that signal was to name a high school after a Confederate general. Those school board members of the late 1950s are many years gone, but the judge found their actions still quite relevant today — a reminder to local officials everywhere that the actions they take today sometimes cast long shadows.
The judge’s opinion finds that a more recent school board member, Dennis Barlow, undermined the county’s position in support of the Confederate names when he declared at one meeting that whatever happened then doesn’t matter now: “If there was a so-called ‘massive resistance’ movement, it was neither massive nor actively pursued. In any case, any resentment over the issue has evaporated long ago and is therefore now irrelevant.”
For more reading
For those interested in learning more about Massive Resistance, I recommend “We Face the Dawn,” by Virginia journalist Margaret Edds that tells the story of the Virginia lawyers who helped bring down segregation, Oliver Hill and Spottswood Robinson.
This is simply not true, and while I have no insight into Urbanski’s ruling beyond his opinion, it’s easy to imagine that Barlow’s denial of basic historical facts struck the judge as one worthy of some stern correction. Massive Resistance was quite massive and was actively pursued, from U.S. Sen. Harry F. Byrd Sr. and two governors on down to local school boards across Virginia. It’s astonishing that a school board member does not know this. Massive Resistance was massive enough that four localities — Charlottesville, Norfolk, Prince Edward County and Warren County — shut down their schools entirely rather than integrate. In Prince Edward County, schools were closed for five years.
Many white Virginians may have forgotten this, if they ever knew it in the first place, but many Black Virginians remember this all too clearly — that resentment did not evaporate and remains quite relevant, whether white Virginians want to acknowledge it or not. There remain among us fellow Virginians who were denied a chance to attend school because of Massive Resistance. If we cannot accept these basic facts, it’s hard to have a rational conversation about the differences of opinion that still arise over the choices made during Massive Resistance almost seven decades later. Urbanski quoted legal cases, but I’ll quote William Faulkner: “The past is never dead. It’s not even past.” This case proves the truth of that aphorism.
What the judge said
“This is not a case in
which students brought a lawsuit to change a school name that had been continuously in place
for many years. Rather, it is a case about students suing over the School Board’s 2024 decision
to reinstate school names that the School Board itself removed four years earlier as being
racially discriminatory. Nor is this case about the appropriate legacy of the three Confederate
officers for whom the schools were named. While that debate casts cultural, historical, and
political shadows over this case, often evoking strong emotions, the issues to be decided here
are entirely legal in nature and turn on the elements of the legal claims, burden of proof, and
evidence presented.”
This is where Urbanski draws the line that he says separates “the unique facts of this case” from some other generic challenge against a Confederate name. “This is not a case,” he wrote, “about a longstanding nickname, left in place by inertia and the path of least resistance. Rather, it concerns whether the act of restoring a school name which had been removed because it was linked to racial division and segregation violates the School Board’s affirmative duty to eliminate racial discrimination ‘root and branch.’”
Put another way, the Shenandoah County school board in 2024 knew very well that the Confederate names had been chosen for a racial reason, that they had been changed to try to remove that taint, but the school board decided to restore the names anyway.
“From the voluminous record in this case, the court can readily trace the connection between the Confederate names and the de jure system of segregation,” Urbanski wrote. “The School Board originally chose the name Stonewall Jackson in furtherance of Massive Resistance to public school desegregation. The name was chosen for an all-White high school, which Blacks were not permitted to attend when it opened in 1959. The selection of the name Stonewall Jackson High School was intended to dissuade Black students from requesting transfers into that school, in furtherance of the dual school system. The School Board also named another school, Ashby-Lee Elementary School, in 1974, following an active period of federal school integration enforcement.”
Shenandoah County argued that any link between the names and Massive Resistance expired long ago — and was broken when the county briefly retired the names. When the county brought the names back, it wasn’t trying to invoke Massive Resistance, it was simply trying to restore names that the many residents considered traditional.
Possible new names?
In a column two years ago, I pointed out three historical figures from Shenandoah County who haven’t received their due:
Col. Florence Aby Branchfield. She led the Army Nurse Corps during World War II and was buried with military honors in Arlington National Cemetery.
Leslie Coffelt. He was a White House police officer who was slain protecting President Truman during an assassination attempt in 1950.
Harrison Riddleberger: As a state legislator in the 1880s, his legislation set the fiscal stage for the state’s first public school system.
Urbanski didn’t buy that argument. “This argument is unsupported by the evidence in this case,” he wrote. “There was no showing that the Confederate names ceased to have a discriminatory impact at the time the School Board chose to restore them — in fact, the information before the School Board, and the evidence before the court, indicates quite the opposite. The brief period in which the Confederate names were not on the buildings did not erase the history of the original selection of the names, nor did it erase the impact of the names on Black students. Rather, the Confederate names were restored with complete awareness of their historic legacy and ongoing discriminatory impact. In the court’s view, the affirmative act of reinstating these vestiges of segregation is far more problematic than a passive failure to remove a long-standing name or symbol.”
The short version: Urbanski sees his ruling in the light of the Brown v. Board of Education cases. “The causal link is clear,” he wrote, “Shenandoah County’s Confederate school names are traceable to the de jure system of segregation in Shenandoah County.”
In writing his order for the county to change the names, he deliberately invoked the language from Brown, specifically the follow-up 1955 case known as Brown II. The court, Urbanski wrote, orders Shenandoah County to remove the names and adopt new ones “on a racially nondiscriminatory basis with all deliberate speed.”
Seven decades after the Brown case, a judge in Virginia sees himself still working to make sure that order is enforced.
The judge’s opinion and his separate court order:
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