In the case of Joy v. Adelbert College in 1892, the U.S Supreme Court was tasked with deciding whether a college could change its name without losing an endowment left to it by a benefactor. The original donor, Amasa Stone, had given $500,000 to Western Reserve College under the condition that it be renamed after his son, Adelbert Stone. After Stone's death and following financial difficulties at the institution which led them to consider merging with another university (Case School of Applied Science), there were concerns about retaining their ability to use this endowment if they changed their name again. The court ruled in favor of Adelbert College stating that as long as the purpose for which funds are donated is being fulfilled - i.e., education - then changes such as renaming do not violate conditions set forth by donors or invalidate gifts made on those grounds. This decision established important precedent regarding donor intent and institutional autonomy within higher education law.

In the dissenting opinion for Joy v. Adelbert College, it was argued that the college should not be allowed to change its original purpose and use funds donated by Amasa Stone for a different cause than what he had intended. The justices in disagreement believed that Stone's donation was made with specific conditions attached - namely, to fund an institution of higher learning named after his son, Adelbert Stone. They contended that allowing such a deviation from the donor's intent would set a dangerous precedent where institutions could freely repurpose donations without considering donors' wishes or stipulations. This view held up principles of trust law and contract law as paramount over any perceived benefits gained from altering the use of funds posthumously.