Fresno County lacks the legal standing to challenge a state law banning derogatory place names, a state appeal court affirmed. (GV Wire Composite/Paul Marshall)

- State law AB 2022, effective Jan. 1, 2025, prohibits using "squaw" for geographic locations like Yokuts Valley.
- The court stated residents, not the county, must assert claims regarding free speech or association rights in the name change.
- County supervisors previously rejected the federal name change to Yokuts Valley, favoring Bear Valley instead.
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A state appeal court ruled that Fresno County does not have standing when challenging a lawsuit over a state law banning derogatory place names. And one county supervisor says the fight is over.
A 3-0 ruling from the Fifth Appellate District found in favor of the state and ordered the county to pay undetermined court costs.
Fresno County sued the state in 2023 over AB 2022, which banned the use of “squaw” for geographic place names. The law went into effect Jan. 1, 2025. “Squaw” is considered a derogatory term for Native American women.
Approximately 3,000 residents live in the unincorporated mountain community that until recently was known as Squaw Valley, about 30 miles east of Fresno on Highway 180. The federal government — during the Biden Administration — recognized the community as Yokuts Valley.
“I am disappointed with the appellate court ruling regarding the lawsuit that the county had against the state, but I also respect that ruling,” said supervisor Nathan Magsig, who represents the community.
Magsig said the county would follow the law.
“The county has lost at the Superior Court, and now the appellate court level. There are no plans to appeal further,” Magsig said.
Public agencies were to submit alternate names to the California Advisory Committee on Geographic Names by Aug. 6, 2024. The official list of Fresno County names needing to be replaced include the CalFire station, the Squaw Valley Cemetery, Squaw Valley Road, and Squaw Leap Lane.
The state challenged the nature of a lawsuit in Fresno County Superior Court through an action called a demurrer, and Judge D. Tyler Tharpe sustained the action. He agreed with the state’s argument that the county did not have standing.
Tharpe did allow the county to file an amended suit, but dismissed the case when the county did not follow through. The county then appealed the dismissal, challenging the state’s authority to rename the area.
The Fresno County Board of Supervisors in 2022 voted to reject the federal name change, and said if there was a renaming, it should be Bear Valley. Also, voters in 2024 rejected a charter amendment that would specifically give the supervisors name-change authority.
Representatives from the state were immediately available for comment.
The Court’s Opinion
The court, citing several prior court cases, rejected the county’s arguments in a 38-page opinion issued Tuesday.
“The mere assertion that a name change for the Community is opposed by certain Community residents, and that the County is aligned with their opposition, does not persuade us that County’s challenge to a general law of the state is a valid exercise of its police powers,” Associate Justice Kathleen Meehan — a Jerry Brown appointee — wrote.
Acting Presiding Judge Bert Levy (appointed by Pete Wilson), and Associate Justice Thomas DeSantos, another Brown appointee, concurred.
One of the key arguments is the county has standing to bring the lawsuit. The appeal court disagreed.
“Because County has not alleged any facts to demonstrate Community residents and business owners would face any substantial obstacles in asserting their own rights in this matter, we conclude County does not have standing to assert the free speech and association rights of its constituents,” Meehan wrote.
Meehan also wrote that the law contains “suitable safeguards … to protect against misuse,” when it comes to a state advisory committee on names making decisions.
Even if the argument that the law requires the county to accept certain state views — that “squaw” is a racist term — it is an argument to be made by the residents, and not the county, Meehan wrote.
The court, in a footnote, said “We mean no disrespect to Native Americans and those who are offended by the term” for using the actual “squaw” name in its ruling.
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