Dr. Larry Chavis, a non-tenured clinical professor at the University of North Carolina’s business school, sued the University and the Dean of the Business School (Mary Margaret Frank) after UNC declined to renew his annual teaching contract in 2024. Dr. Chavis alleged that the decision was motivated by race discrimination, retaliation for his internal complaints about diversity and equity issues, retaliation for publicly criticizing UNC’s handling of diversity initiatives, and retaliation for exercising his First Amendment rights.
Dr. Chavis had been employed by UNC in various faculty roles since 2006. During his tenure, he was outspoken on issues relating to diversity, equity, and inclusion, frequently posting on social media, writing emails to university leadership, and making internal complaints alleging a lack of diversity and inequitable treatment within the business school. Despite these public criticisms, UNC appointed him as interim and later permanent director of the American Indian Center, nominated him for a national fellowship, and promoted him to full clinical professor in 2022.
The events leading to the non-renewal began during the 2023-2024 academic year. Several graduating students complained to business school administrators that Dr. Chavis’s undergraduate international development course differed substantially from its catalog description and syllabus. According to the students, class sessions frequently became discussions of Dr. Chavis’s personal employment disputes with UNC and his views on diversity-related issues, rather than the advertised course content. Students also reported that Dr. Chavis sometimes humiliated students in class, required them to comment on his personal circumstances as part of graded participation, and created an atmosphere in which students feared retaliation if they disagreed with him or complained about the course. Some students specifically expressed concern that he might publicly identify them, citing an earlier instance in which Dr. Chavis had posted a negative student evaluation on LinkedIn.
In response to those complaints, school administrators initially arranged to record several class sessions after obtaining approval from Human Resources. They did not tell Dr. Chavis in advance that these recordings would occur. When Dr. Chavis learned about the recordings, he protested, and publicly criticized the decision through news interviews and social media, claiming that they violated UNC policy. Thereafter, the University agreed instead to conduct in-person classroom observations as part of a formal teaching evaluation.
The resulting evaluation concluded that Dr. Chavis had significantly altered the course content without obtaining required approval, failed to revise the syllabus or course description, devoted substantial class time to his own employment disputes with UNC, and created a classroom environment in which students feared embarrassment or retaliation. The evaluation also acknowledged that many students had submitted positive evaluations, but nevertheless concluded that the concerns regarding course content and classroom climate warranted corrective action.
After reviewing the evaluation, Dean Frank decided not to renew Dr. Chavis’s contract. She testified that her decision was based on the findings that he had taught material inconsistent with the approved curriculum and that student safety and classroom climate concerns weighed heavily in her decision.
The Court granted summary judgment in favor of the University and Dean Frank on all claims.
With respect to the retaliation claims under Title VII and 42 U.S.C. § 1981, the Court assumed that Dr. Chavis had engaged in protected activity by publicly criticizing the University and raising concerns about diversity issues. However, the Court concluded that UNC articulated legitimate, non-retaliatory reasons for the non-renewal: namely, the findings contained in the teaching evaluation, and that Dr. Chavis failed to produce evidence that those reasons were pretextual. The Court emphasized that disagreement with the evaluation did not establish retaliation, nor did the close timing between his public criticism and the non-renewal overcome the substantial evidence in the teaching evaluation, supporting UNC’s stated reasons.
The Court likewise rejected Dr. Chavis’s race discrimination claim under Title VII. Although he argued that racial bias motivated some of the student complaints and that a similarly situated white professor received more favorable treatment, the Court found no evidence that any of the decisionmakers harbored racial animus or that race played any role in Dean Frank’s decision. The Court further observed that UNC had repeatedly promoted and supported Dr. Chavis throughout the same period in which he publicly criticized the institution’s diversity efforts, undermining any inference of discriminatory intent.
Finally, the Court dismissed Dr. Chavis’s First Amendment retaliation claim. The Court recognized that public university faculty possess First Amendment protections but explained that Dr. Chavis still had to demonstrate that his protected speech caused the adverse employment action. The undisputed evidence showed that Dean Frank based her decision on the teaching evaluation rather than on Dr. Chavis’s social media activity or public criticism of the University. The Court also noted that the decision to record his classes was made by other administrators (not Dean Frank) and therefore could not support his claim against her.
Accordingly, the Court entered summary judgment for both defendants on all claims.
Chavis v. Univ. of N. Carolina-Chapel Hill (M.D.N.C. June 30, 2026) 2026 WL 1875746.
Note: For schools conducting investigations into faculty performance, this case highlights that relying on multiple sources of information, including student complaints, classroom observations, written evaluations, and documented review processes, can support a school’s employment decisions.