## Facts

- John W. Sterling, a Yale alumnus, died in 1918 and left funds in trust for Yale University to erect buildings as a memorial.
- The trust gave trustees broad discretion, with limits that funds could not be used to buy land or be placed in Yale’s general fund; no enforcement rights were reserved to Sterling’s heirs.
- In 1930, trustees funded the erection and maintenance of the Yale Divinity School quadrangle bearing Sterling’s name.
- In the 1990s, Yale studied the divinity school’s future; in 1996, Yale’s governing body approved a reorganization plan that included demolishing large portions of the Sterling Divinity Quadrangle.
- Plaintiffs included (1) an asserted heir and successor in interest to Sterling, (2) alumni who graduated from and donated money to the divinity school, and (3) then-current divinity school students.
- Plaintiffs sought injunctive and declaratory relief and an accounting, alleging the plan violated the charitable trust and constituted an abuse of trustee discretion.
- The trial court dismissed for lack of subject matter jurisdiction, concluding plaintiffs lacked standing; plaintiffs appealed.

## Issues

1. Whether an heir of a charitable settlor has standing to enforce or challenge administration of a charitable trust when the trust instrument reserves no enforcement rights.
2. Whether alumni donors and graduates have standing, based on unrestricted charitable gifts and alumni status, to challenge a university’s alleged abuse of discretion in administering charitable gifts and trust-funded facilities.
3. Whether current students have standing to challenge university management decisions about reorganization and demolition absent special injury or infringement of fundamental rights.
4. Whether the attorney general’s decision not to participate permits private plaintiffs to sue under a “special interest” theory.

## Decision

- The appellate court affirmed the dismissal for lack of subject matter jurisdiction.
- The heir lacked standing because the charitable instrument reserved no enforcement authority to the settlor’s heirs or successors.
- Alumni donors and graduates lacked standing because unrestricted gifts and alumni status did not create a legally cognizable, particularized interest.
- Students lacked standing because they alleged no special injury or violation of fundamental rights and were challenging institutional management decisions.
- The attorney general’s nonparticipation did not supply standing; plaintiffs did not qualify under any narrow “special interest” exception.

## Legal Principles

- Enforcement of a charitable trust is ordinarily a public function carried out by the state attorney general or another authorized public official, not by private parties.
- A settlor’s heir does not have standing to enforce a charitable trust absent an express reservation of enforcement rights in the trust instrument.
- Donors of unrestricted charitable gifts generally lack standing to control or enforce a charity’s use of those gifts without specific enforceable conditions or reserved rights.
- Students generally lack standing to contest the manner in which a university is managed unless they show a special injury or an infringement of fundamental rights.
- The “special interest” basis for private standing in charitable-trust matters is narrowly confined to plaintiffs with a direct, individualized interest distinct from that of the general public or a broad beneficiary class.

## Conclusion

The court held that an heir, alumni donors, and students could not sue to block Yale’s divinity school reorganization or enforce the Sterling charitable trust because none had a legally sufficient special interest or individualized injury; absent reserved enforcement rights, oversight of charitable trusts rests with the attorney general.


Russell v. Yale Univ., 54 Conn. App. 573, 737 A.2d 941 (Conn. App. Ct. 1999)