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Free Speech

Renaming Streets "Cesar Chavez Boulevard" Didn't Violate First Amendment

Eugene Volokh | 8.24.2026 8:01 AM

From 1 Community Compact v. City of Fresno, decided Friday by California Court of Appeal Justice Jennifer Detjen, joined by Justice Donald Franson:

Emphasizing the "profound impact" of Mexican-American labor leader and civil rights activist Cesar Chavez "on the people of Fresno" and concluding the renaming of a downtown thoroughfare in his honor would "provide a source of pride and community recognition," the Fresno City Council … adopted Resolution No. 2023-056, which facilitated the renaming of the "East Kings Canyon Road, East Ventura Avenue, and West California Avenue alignment" (collectively, the Alignment) to Cesar Chavez Boulevard.

Plaintiffs objected to the renaming and then sued, among other things arguing thus:

The operative complaint alleges the following. The Alignment is composed of three streets "decidedly historical to [City]'s rich history." East Ventura Avenue, which was named in 1873, "has always been the heart of [City's] Armenian Community" and "was known as Armenian Town." West California Avenue, which was named in 1881, is "the heart" of City's African-American community. East Kings Canyon Road, which "is over 70 years old," "has always been known to residents and tourists alike as the gateway to the Sierras and Kings Canyon National Park."

Cesar Chavez, who was "not a Fresno native and never lived in Fresno," "has never been integral to nor associated with any of these [three] historical streets." He was also a "divisive" and "objectionable political figure" who "alienated many farmers, packing houses and grocery stores and retaliated against those who did not join his union."

Plaintiff "is an unincorporated grass roots association with [more than 1,000] members who live, own, or operate a business on the historic …........

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