Until the early 1970's most private colleges and universities followed conservative investment strategies. To better finance the expanding scope of higher education, many private colleges and universities then began to move increasingly toward common stock. The total return on common stock in the seventies, however, proved insufficient to meet increasing budgetary requirements. In 1978, Duke University, following the lead of other private institutions, further diversified its portfolio by investing $2.16 million of unrestricted endowment funds in unimproved real property. In an analysis applicable to many private colleges and universities across the nation Prof. Christie assesses the legality of this strategy under North Carolina law. Prof. Christie then offers general guidelines for trustees of private colleges and universities seeking to embark on more aggressive investment strategies.