Judge rules for UNC in lawsuit from fired business professor

A federal judge has ruled against a former University of North Carolina business professor who sued the school for retaliation and racial discrimination after his contract was not renewed in 2024.

US Chief District Judge Catherine Eagles issued an order Tuesday granting the university’s motion for summary judgment against Larry Chavis. Chavis had complained about the process the university used to evaluate his job performance, including secret recordings of his classroom instruction.

He sued both UNC and Business School Dean Mary Margaret Frank.

“Dr. Chavis’s claims all run into the same insurmountable hurdle: the evidence is undisputed that UNC and Dean Frank chose not renew his contract because of the teaching evaluation findings, and there is insufficient evidence to support an inference that racial discrimination or retaliation for his public statements caused or played a role in the decision,” Eagles wrote. “Thus, no reasonable jury could find that the defendants’ actions were the result of retaliatory or discriminatory intent, in whole or in part. The defendants’ motion for summary judgment will be granted.”

Chavis started working at UNC in 2006 and held various roles, including director of the campus American Indian Center.

“During his time at UNC, Dr. Chavis frequently posted on social media about events and topics related to diversity, equity, and inclusion,” Eagles wrote. “His posts were often highly critical of the approach taken by UNC and the business school to these issues.”

“He also regularly communicated his concerns to his colleagues and other UNC faculty,” the court order continued. “Some of these emails addressed broader institutional or societal situations, while others focused on his personal circumstances at the university. In a 2020 email to the chancellor and the provost, Dr. Chavis expressed his belief that he had been passed over for promotions and his disappointment about a perceived lack of diversity at the business school.”

After Frank became dean, she met with Chavis in February 2024. In an email following that conversation, “Dr. Chavis expressed frustration with his lack of career advancement at UNC and explained that he limited his time and interactions at the business school because of his perception that other faculty members ‘hate [him] for being too truthful and too supportive of equity,’” according to Eagles’ opinion.

In a separate meeting that month, an associate dean notified Chavis that his contract would be renewed for another year.

That spring, “several” graduating students told a different associate dean that they had “serious concerns about Dr. Chavis’s undergraduate international development class.”

“They reported that the course content did not align with its description in the course catalog; that the course was poorly organized and ‘essentially was a stream of consciousness conversation’ about Dr. Chavis’s personal issues; and that Dr. Chavis humiliated certain students because of, for example, their race and fraternity affiliation,” Eagles wrote.

Two school officials then decided to conduct secret recordings of Chavis’ classes.

In March 2024, Frank sought a teaching evaluation of Chavis’ work. “As part of that process, Dr. Chavis learned about the recordings and protested that they violated UNC policy,” Eagles wrote. “He also gave a series of interviews about the recordings with local and online news outlets, and posted on social media about articles covering the incident.”

The evaluation “examined the course syllabi, student reports, and recent student written evaluations, and considered in-person faculty observations,” the court order explained. Evaluators produced a written report.

“First, Dr. Chavis had changed the course’s content to focus on indigenous issues without approval and without revising his syllabus, course name, or course catalog description,” Eagles wrote. “Second, Dr. Chavis had replaced the course content with discussion of his personal and professional situation and his dissatisfaction with some of UNC’s decisions, which created an environment that required students to discuss his personal circumstances during class and created a fear of retaliation if he disapproved of a student’s contributions.”

“Third, in course evaluations, several students expressed concerns about Dr. Chavis’s course content and teaching methods, though the report noted that there were also many positive evaluations,” Eagles added. “Finally, during in-person teaching observations, Dr. Chavis ‘covered content inconsistent with’ the course description, including ‘some limited discussion of his personal situation.’”

“The evaluators concluded that the examination ‘uncovered several issues regarding content and conduct, including students reporting safety issues and fear of retaliation,’” the court order continued.

Frank reviewed the report and decided not to renew Chavis’ contract. He filed suit after that decision.

“Dr. Chavis has presented no direct evidence that Dean Frank did not renew his contract in retaliation for a protected activity, and he does not assert that there is any such direct evidence,” Eagles wrote. “Nor is there circumstantial evidence sufficient to raise an inference of such retaliation.”

“Dr. Chavis identifies his protected activity as his interviews with local media outlets and online publications and his postings online in the spring of 2024 criticizing the recording of his classes without his knowledge, which he contends was linked to racial discrimination,” the judge added. “He points to the temporal proximity of those public complaints to the decision not to renew his contract as supporting an inference of causation.”

“[T]he defendants have articulated a legitimate, nonretaliatory reason for their actions,” Eagles wrote. “All available evidence shows that Dean Frank’s decision not to renew Dr. Chavis’s contract was based on the findings made during the teaching evaluation of his international development class.”

Frank “testified that the ‘deciding factor’ for not renewing Dr. Chavis’s contract was that he ‘had chosen to teach material that had not gone through the process of being approved, and that [he] was thus teaching content that was not what we were expecting in the program,’” the court order continued. “She has also testified that concerns about the physical and psychological safety of UNC’s students motivated her decision.”

Eagles rejected Chavis’ claims of racial discrimination.

“Dr. Chavis contends that there is evidence that race played a part in Dean Frank’s decision,” the judge wrote. “He asserts that racial animus motivated the negative student feedback Dr. Chavis received, that Dean Frank relied at least in part on that feedback when she decided to end Dr. Chavis’s employment, and as a result Dean Frank’s decision was infected with racial animus.”

“There are at least two problems with that contention,” Eagles explained. “First, the students who complained about Dr. Chavis’s course were not decisionmakers. Second, there is no evidence to support an inference that Dr. Chavis’s race motivated the negative student feedback. The comments provided in the evaluation report reflect the same concerns expressed by Dean Frank: that Dr. Chavis’s course content did not match the course description, that he went off on unrelated tangents, and that his classroom behavior and previous posts about a student who gave his course a poor evaluation made some students fear that Dr. Chavis might humiliate them or give them a bad grade if they did not express agreement with his beliefs.”

“Judge rules for UNC in lawsuit from fired business professor” was originally published on www.carolinajournal.com.