## Facts

- Matthew James Lovelace was hired by Southeastern Massachusetts University as an untenured faculty member under a one-year teaching appointment running from September 1, 1982, to June 30, 1983.
- His appointment incorporated a collective bargaining agreement between the university’s trustees and the faculty federation.
- Student complaints arose that Lovelace’s courses were overly difficult and required excessive homework.
- After discussions with Lovelace and adjustments to lower-level courses, the university decided not to renew his contract after the one-year term ended.
- Lovelace filed a federal civil rights action under 42 U.S.C. § 1983, alleging constitutional violations arising from the nonrenewal and related conduct.

## Issues

1. Whether a non-tenured professor on a fixed, one-year contract had a constitutionally protected property interest in reappointment requiring procedural due process before nonrenewal.
2. Whether the nonrenewal, and the reasons given for it, infringed a constitutionally protected liberty interest by imposing a stigma that harmed reputation or foreclosed future employment.
3. Whether provisions in the collective bargaining agreement requiring “justification” for reappointment or nonrenewal recommendations created a legitimate claim of entitlement to renewal.

## Decision

- The First Circuit affirmed the district court’s summary judgment for the university and its officials.
- The court held Lovelace had no constitutionally protected property interest in continued employment beyond the contract’s definite end date.
- The court held Lovelace showed no constitutionally protected liberty interest was implicated by the nonrenewal.
- Because no protected property or liberty interest was shown, Lovelace was not entitled to a due process hearing or comparable pre-nonrenewal procedures.

## Legal Principles

- Procedural due process protections in public employment require either (a) a protected property interest in continued employment or (b) an infringement of a protected liberty interest.
- A clear, fixed-term appointment generally creates no property interest in employment beyond the term absent an explicit tenure-like guarantee or comparable commitment to renewal.
- Collective bargaining provisions directing evaluators to provide “justification” for renewal or nonrenewal recommendations may be treated as internal procedural requirements and do not, without more, create a substantive entitlement to reappointment.
- A liberty interest is not implicated by nonrenewal absent public dissemination of false, stigmatizing charges of a kind that seriously damages reputation or effectively bars other employment opportunities.

## Conclusion

The First Circuit ruled that the university’s decision not to renew an untenured professor’s one-year contract did not trigger constitutional due process protections because the professor lacked any enforceable entitlement to renewal and failed to show any stigmatizing publication sufficient to establish a liberty-interest claim.


Lovelace v. Se. Mass. Univ., 793 F.2d 419 (1st Cir. 1986)