Beitzell v. Jeffrey
United States Court of Appeals for the First Circuit
643 F.2d 870 (1981)
Beitzell (plaintiff) was an assistant professor of history at the University of Maine. In the fall of 1971, Beitzell was first considered for tenure. The history department’s Policy Advisory Committee (PAC) recommended to the department chairman, Jeffrey (defendant), that Beitzell not receive a tenured position. Jeffrey accepted that recommendation. During this time, Jeffrey believed that Beitzell drank too much based on faculty rumors, and this was known to members of the PAC. Beitzell was again considered for tenure in the fall of 1972, and again the PAC recommended against tenure, which Jeffrey again accepted. Beitzell appealed to the Faculty Professional Relations Committee, which agreed with the PAC’s decision. Beitzell then filed a grievance seeking a hearing with the university’s Grievance Board, which allowed both parties to present evidence and examine and cross-examine witnesses. The Grievance Board advised the PAC to give Beitzell further consideration. Regardless, the PAC voted to not reopen Beitzell’s case, which was affirmed by the university’s president. Beitzell filed a lawsuit alleging that he was deprived of both liberty and his property interest in tenure without adequate due process. The district court ruled in favor of Jeffrey, and Beitzell appealed.
Rule of Law
Holding and Reasoning (Breyer, J.)
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