## Facts

- Mary Anne Hedrich was a tenure-track assistant professor at the University of Wisconsin–Whitewater.
- The university denied her tenure, citing failure to meet scholarship standards and failure to submit relevant documentation for departmental review.
- She was informed the following academic year would be her terminal year.
- Hedrich applied for several academic positions and was unsuccessful.
- She sued the Board of Regents and university officials, alleging sex discrimination under Title VII, denial of equal protection, and deprivation of a liberty interest in future employment without due process based on alleged reputational harm.

## Issues

1. Whether Hedrich produced sufficient evidence that the tenure denial was motivated by sex discrimination in violation of Title VII and the Equal Protection Clause.
2. Whether the tenure denial and related criticisms deprived Hedrich of a constitutionally protected liberty interest in future employment, requiring due process.

## Decision

- The Seventh Circuit affirmed the judgment for the defendants.
- Summary judgment on the Title VII and equal protection claims was proper because the record would not permit a reasonable factfinder to infer discriminatory intent.
- Summary judgment on the due process claim was proper because Hedrich did not show the required “stigma-plus” deprivation of a liberty interest.
- The court noted Hedrich’s failure to comply with local summary-judgment procedures, but reviewed the merits in any event.

## Legal Principles

- In discrimination challenges to academic tenure decisions, a plaintiff must present evidence that unlawful bias, not academic judgment, motivated the adverse decision.
- Under Rule 56, once the movant supports a summary-judgment motion with evidence, the nonmovant must identify genuine disputes of material fact.
- A procedural due process liberty-interest claim based on reputational harm requires “stigma-plus”: false and stigmatizing charges made public in connection with an alteration of legal status (such as termination) that effectively foreclose other employment opportunities.
- Professional criticisms of scholarship or performance, without public dissemination of false statements implying dishonesty or moral turpitude, generally do not satisfy the stigma requirement.
- Unsuccessful applications for other jobs, standing alone, do not establish that the government imposed a constitutional bar to future employment.

## Conclusion

The court held that Hedrich failed to produce evidence supporting an inference that sex discrimination caused the denial of tenure and failed to show publicly disseminated, false, stigmatizing statements that, combined with the tenure decision, deprived her of a protected liberty interest; the judgment for the university defendants was affirmed.


Hedrich v. Bd. of Regents of Univ. of Wis. Sys., 274 F.3d 1174 (7th Cir. 2001)