ethnic studies with American studies have been met with fierce opposition as was the case at UC Berkeley. While the field is already decades old, the ongoing creation of new ethnic studies departments is fraught with controversy. Administrators at Columbia University attempted to placate student protests for the creation of an Ethnic Studies Department in 1996 by offering American Studies as a compromise. Arizona ban On May 11, 2010, Arizona Governor Jan Brewer signed House Bill 2281 (also known as HB 2281 and A.R.S. §15–112), which prohibits a school district or charter school from including in its program of instruction any courses or classes that Promotes the overthrow of the Federal or state government or the Constitution Promotes resentment toward any race or class (e.g. racism and classism) Advocates ethnic solidarity instead of being individuals Are designed for a certain ethnicity But the law must still allow: Native American classes to comply with federal law Grouping of classes based on academic performance Classes about the history of an ethnic group open to all students Classes discussing controversial history Coming off the heels of SB 1070, Superintendent of Public Instruction Tom Horne was adamant about cutting Mexican-American Studies in the Tucson Unified School District. He devised HB 2281 under the belief that the program was teaching "destructive ethnic chauvinism and that Mexican American students are oppressed". In January 2011, Horne reported TUSD to be out of compliance with the law. In June of that year, the Arizona Education Department paid $110,000 to perform an audit on the TUSD's program, which reported "no observable evidence was present to suggest that any classroom within the Tucson Unified School District is in direct violation of the law." John Huppenthal (elected Superintendent as Horne became Attorney General) ordered the audit as part of his campaign promise to "Stop La Raza", but when the audit contradicted his own personal findings of noncompliance, he discredited it. Despite a formal appeal issued on June 22, 2011 by TUSD to Huppenthal, Judge Lewis Kowal backed the Superintendent's decision and ruled the district out of compliance in December, 2011. On January 10, 2012 the TUSD board voted to cut the program after Huppenthal threatened to withhold 10% of the district's annual funding. Numerous books related to the Mexican-American Studies program were found in violation of the law and have been stored in district storehouses, including William Shakespeare's The Tempest, Paolo