Soni v. University of Tennessee

Dr. Raj P. Soni (plaintiff) was a visiting professor of mathematics at the University of Tennessee (Tennessee) (defendant). Soni had numerous discussions with John Barrett, the department head, about the possibility of receiving tenure with Tennessee. Soni was told that a decision about his employment would be made the following year. Shortly after, Barrett wrote a recommendation letter for Soni, in which he recommended that Soni be offered an associate professorship with tenure. Less than a month later, Donald Dessart, the acting head of the department, called a meeting to consider Soni’s employment. At the meeting, it was pointed out that Soni, a noncitizen, could not be appointed to a permanent position because of a state law barring noncitizens from full-time appointments at state universities. No formal vote took place at the meeting. Soni’s status was officially changed from a full-time visiting professor to an associate professor. Soni received a letter informing him that he would be considered for tenure upon attaining citizenship. Soni was enrolled in the retirement program, which was reserved for permanent faculty, and he was promised that he would be treated like any other tenured professor. For the next two years, Soni continued teaching and had many privileges reserved for tenured professors, such as attending department meetings and voting on tenure appointments. Faculty members offered Soni verbal assurances. Soni eventually obtained citizenship, but Tennessee terminated his appointment because of his performance as a teacher and researcher. There was no hearing conducted. Soni sued Tennessee, alleging a violation of procedural due process. A trial court ruled in Soni’s favor, finding that he had a cognizable property interest in his continued employment. Tennessee appealed, emphasizing that it had a formal tenure system in place to ensure that nontenured professors would not have an expectation of continued employment.