University of Minnesota v. Goodkind

Richard Goodkind taught at the University of Minnesota (Minnesota) (defendant) in the dental school. A tenured professor, Goodkind applied for the position of chairperson of the Department of Fixed Prosthodontics after the dean of the school, Richard Oliver, appointed a search committee. Goodkind was the only person recommended by the search committee. Despite this, Oliver decided not to appoint Goodkind, citing his inexperience in administering budgets and teaching prosthodontics, as well as differences in educational goals. Oliver appointed an acting chairperson and eventually another search committee. At the time, the board of regents of the dental school had adopted a Dental School Constitution (the constitution), the purpose of which was to define the purpose, authorities, and responsibilities of the dental school. The constitution provided that applicants for chairpersons and department heads shall be appointed by the dean from the recommendations of the search committee. Goodkind’s employment contract did not contain such a provision. Goodkind filed a suit alleging breach of contract, predicated on the argument that the constitution became part of his employment contract, and that by not appointing him, Minnesota breached the contract. Minnesota argued that the constitution was not part of Goodkind’s employment contract. A district court sided with Goodkind, finding that the constitution became part of Goodkind’s employment contract, and that Minnesota had breached it. Minnesota appealed the decision.