Attard v. Benoit et al.

2007 DNH 155
District Court, D. New Hampshire·Decided December 12, 2007·No. CV-06-355-PB·Published·Cited by 1 cases

Opinion

Attard v . Benoit et a l . CV-06-355-PB 12/12/07 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Thomas L . Attard

v. Civil N o . 06-cv-355-PB Opinion N o . 2007 DNH 155 Jean Benoit, et a l .

MEMORANDUM AND ORDER

Thomas Attard was hired as a tenure-track faculty member in

the civil engineering department at the University of New

Hampshire (“UNH”). After receiving a notice of non-

reappointment, Attard sued UNH and Jean Benoit, chairman of the

civil engineering department. He asserts claims for wrongful

termination, breach of contract, misrepresentation, and tortious

interference with a contractual relationship. UNH and Benoit

have moved for summary judgment. For the reasons that follow, I

grant the motion in part and deny it in part.

I. BACKGROUND1

A. Letter of Appointment

Attard accepted a tenure-track position as an Assistant

Professor of Civil Engineering at UNH in April 2003. His letter

1 I construe the facts in the light most favorable to Attard, the non-moving party. See Latin Am. Music C o . v . Archdiocese of San Juan of the Roman Catholic & Apostolic Church, 499 F.3d 3 2 , 38 (1st Cir. 2007). of appointment states that his job will begin on August 2 3 , 2003,

and that UNH will make a decision on tenure “no later than July

2009.” Attach. to Ex. 1 , Mot. for Summ. J. (June 2 7 , 2007)

(Letter from Jean Benoit to Thomas Attard, at ¶ 1 (May 1 , 2003)).

The letter also specifies that

You will also be provided with a start-up fund of $105,000, which you can use to support your research initiation efforts including the purchase of equipment, 2/9th of summer salary, summer graduate support and other related scholarly activities. An additional amount of $15,000 would be made available as matching money for a research grant proposal for external funding for the construction of a Ling machine. The use of the College of Engineering and Physical Sciences machine shop will also be provided at no-cost for the first three years towards the fabrication of the Ling machine. This start-up fund will be provided to you over a period of 2 to 3 years.

Id. The letter does not explicitly identify the length of

Attard’s employment contract. Nor does it provide any additional

details concerning his terms of employment. Instead, it states

that Attard’s employment will be “governed by the UNH American

AAUP Collective Bargaining Agreement.” Id. Article 14 of the

relevant Collective Bargaining Agreement provides:

Appointments of non-tenured bargaining unit members expire at the end of each appointment year (academic or fiscal). Notice of non-reappointment shall be given to faculty based on the faculty member’s length of service

-2- at the end of the appointment year: • One (1) year or less; notice by March 1 • Greater than one (1) year but less than two ( 2 ) ; notice by December 15 • Equal to or greater than two (2) years; notice twelve (12) months prior to the expiration of the appointment. (For purposes of this Article only, academic year appointments are assumed to expire on May 15 t h . Fiscal year appointments expire on June 30 th .)

Collective Bargaining Agreement, University of New Hampshire, and

University of New Hampshire Chapter of the American Association

of University Professors, § 141 (July 1 , 2003 - June 3 0 , 2006)

(“CBA”). The CBA also states

At the time of initial appointments, a tenure-track faculty member shall be notified in writing that a decision on tenure in his/her case will be reached no later than the end of a certain number of years of full-time service. A tenure decision may be reached before the time so stated, but it shall not be deferred beyond that time. An affirmative tenure decision shall lead to the award of tenure, effective the first day of the following appointment year. A negative tenure decision in the mandatory year shall be followed by a notice of non-reappointment effective at the end of the following appointment year.

2003 CBA at § 13.9.1.

B. Employment History

The relationship between Attard and Benoit became

increasingly tense during Attard’s employment. Beginning in the

fall of 2003, Benoit made inappropriate sexual comments about

-3- female students in Attard’s presence and suggested that one of

Attard’s foreign Ph.D. students looked like a terrorist. Attard

expressed disapproval of Benoit’s comments and later reported

them to the University’s Affirmative Action and Equity Office in

October 2005.

Benoit also interfered with Attard’s research and teaching.

In the fall of 2003, Benoit urged Attard to include two

department colleagues, Professors Bell and Cook, in Attard’s

research proposal for the development of a shaking table

facility. The inclusion of Bell and Cook slowed Attard’s

research significantly. Cook’s design for the table was faulty

and had to be changed in the summer of 2004. In addition, Bell

was on a year-long paid medical leave for the 2004-05 academic

year. Because of Bell’s absence, Benoit refused Attard’s

November 2004 and January 2005 requests for access to the start-

up funds required to purchase components for the project.

Benoit also asked Attard to teach an extra course in the

fall of 2004 because Bell was on medical leave. This added

responsibility took away from Attard’s research time. In

addition, both of the classes that Attard planned to teach in the

spring of 2005 were cancelled because he was required to teach

-4- another of Bell’s scheduled classes as well as a class that was

regularly taught by Cook. Attard asked Benoit to reconsider the

cancellations and submitted a letter and a list of petitioning

students, but his request was denied.

In the fall of 2004, Benoit disapproved of Attard’s decision

to allow a teaching assistant to cover two of Attard’s class

lectures and criticized Attard for missing too many faculty

meetings. In December 2004, Benoit directed Cook to re-

administer the student evaluations in one of Attard’s classes

because the original evaluations were given before Attard

announced that there would be an exam during the last week of

classes. Attard asked Benoit to reconsider and discussed the

situation with an AAUP representative, but the evaluations were

re-administered and no action was taken on Attard’s letter of

protest to Arthur Greenberg, the Dean of the College of

Engineering and Physical Sciences.

In February 2005, Benoit met with Attard and suggested that

UNH was “not a good fit” for Attard, telling Attard that his

research would be better served by a larger university with Ph.D.

students. Attard consulted with the AAUP in March 2005 to see if

the union could assist with the situation, but the union

-5- representative stated that the union could not help him resolve

the case and recommended that Attard contact an attorney. On May

1 0 , 2005, Attard was notified that Dean Greenberg had accepted

the Civil Engineering Department’s recommendation of non-

reappointment. Attard was instead given a one-year position that

concluded on May 1 5 , 2006.

II. STANDARD OF REVIEW

Summary judgment is appropriate when “the pleadings,

depositions, answers to interrogatories, and admissions on file,

together with the affidavits, if any, show that there is no

genuine issue as to any material fact and that the moving party

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