CARR v. TRUSTEES OF PURDUE UNIVERSITY

CourtDistrict Court, S.D. Indiana
DecidedAugust 14, 2024
Docket1:24-cv-00772
StatusUnknown

This text of CARR v. TRUSTEES OF PURDUE UNIVERSITY (CARR v. TRUSTEES OF PURDUE UNIVERSITY) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CARR v. TRUSTEES OF PURDUE UNIVERSITY, (S.D. Ind. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

STEVEN ALAN CARR, ) DAVID G. SCHUSTER, ) JAMES SCHEURICH, ) DAVID MCDONALD, ) ) Plaintiffs, ) ) v. ) No. 1:24-cv-00772-SEB-MJD ) TRUSTEES OF PURDUE UNIVERSITY, ) TRUSTEES OF INDIANA UNIVERSITY, ) ) Defendants. ) ) ) STATE OF INDIANA, ) ) Intervenor. )

ORDER GRANTING DEFENDANTS' MOTIONS TO DISMISS AND DENYING PLAINTIFFS' MOTION FOR A PRELIMINARY INJUNCTION

Plaintiffs Steven Carr, David Schuster, James Scheurich, and David McDonald (col- lectively "Plaintiffs")—each a tenured professor at an Indiana public university—brought this action against Defendants Trustees of Purdue University and Trustees of Indiana Uni- versity (collectively "Boards"), seeking a preliminary injunction to enjoin the enforcement of Senate Enrolled Act 202 ("SEA 202"), Indiana Code § 21-39.5 et seq. (effective July 1, 2024), which requires the Boards to promulgate and implement policies regarding faculty members' tenure and promotions, on the grounds that SEA 202 violates the First and Four- teenth Amendments to the United States Constitution. Dkt. 8. Intervenor-Defendant State of Indiana ("the State") and the Boards (collectively "Defendants") have moved to dismiss this lawsuit for lack of subject-matter jurisdiction. Dkt. 56, 58.1 For the reasons explained below, the Motions to Dismiss, dkt. 56, 58, are GRANTED and the Motion for Preliminary

Injunction, dkt. 8, is DENIED. BACKGROUND I. SEA 202 Effective July 1, 2024, SEA 202 amends the Indiana Code statutes relating to higher education by creating a new article entitled "State Educational Institutions: The Protection of Free Inquiry, Free Expression, and Intellectual Diversity" and codified as Indiana Code

§ 21-39.5 et seq. SEA 202 directs the boards of trustees of state public higher education institutions, including the Boards of Trustees of Purdue and Indiana University, respec- tively, to adopt new policies aimed at ensuring that faculty members' pedagogies align with the principles of free inquiry, free expression, and intellectual diversity. Pertinent here, section 1(b) provides as follows:

[E]ach board of trustees of an institution shall establish a policy that provides that a faculty member may not be granted tenure or a promotion by the insti- tution if, based on past performance or other determination by the board of trustees, the faculty member is:

(1) unlikely to foster a culture of free inquiry, free expression, and intellectual diversity within the institution; [or]

(2) unlikely to expose students to scholarly works from a variety of political or ideological frameworks that may exist within and are applicable to the faculty member's academic discipline.

1 Rather than file a separate brief, the Boards have moved for joinder with the State's supporting brief, concurring that jurisdictional issues of ripeness and standing, as discussed in the State's Rule 12(b)(1) motion and supporting brief, warrant dismissal of this case and denial of Plaintiffs' re- quested relief. Dkt. 59. The Boards' motion is GRANTED. I.C. § 20-39.5-2-1(b)(1)–(2) ("section 1(b)"). SEA 202 defines neither "free inquiry" nor "free expression" (nor the term "un-

likely"), though it does define "intellectual diversity" as "multiple, divergent, and varied scholarly perspectives on an extensive range of public policy issues." Id. § 21-39.5-1-5. Section 2(a) provides, in relevant part: Not later than five (5) years after the date that a faculty member is granted tenure by an institution and not later than every five (5) years thereafter, the board of trustees of an institution shall review and determine whether the faculty member has met the following criteria:

(1) Helped the institution foster a culture of free inquiry, free expression, and intellectual diversity within the institution.

(2) Introduced students to scholarly works from a variety of political or ideological frameworks that may exist within the curricula established by the:

(A) board of trustees of the institution under IC 21-41-2-1(b);2 or

(B) faculty of the institution acting under authority delegated by the board of trustees of the institution.

Id. § 21-39.5-2-2(a)(1)–(2) ("section 2(a)").3

In evaluating a faculty member's performance under section 2(a), boards of trustees may not consider certain statutorily identified activities conducted by the faculty member,

2 Indiana Code § 21-41-2-1(b) authorizes boards of trustees of state universities to "prescribe the curricula and courses of study offered . . . and define the standards of proficiency and satisfaction within the[m] . . . ." 3 Section 4, which Plaintiffs do not specifically challenge, directs universities to create a reporting mechanism through which third-parties may submit complaints regarding the adequacy of a faculty member's performance, stating, in relevant part, that "[e]ach institution shall . . . [e]stablish a pro- cedure that allows both students and employees to submit complaints that a faculty member . . . is not meeting the criteria described in section 2(a) . . . ." I.C. § 21-39.5-2-4(a)(1). including "(1) [e]xpressing dissent or engaging in research or public commentary on sub- jects"; "(2) [c]riticizing the institution's leadership"; and "(3) [e]ngaging in any political

activity conducted outside the faculty member's teaching or mentoring duties at the insti- tution." Id. § 21-39.5-2-1(c). Nothing in Article 39.5 "may be construed to . . . [l]imit or restrict the academic freedom of faculty members or prevent faculty members from teach- ing, researching, or writing publications about diversity, equity, and inclusion or other top- ics." Id. § 21-39.5-6-1(3). Institutions are also required to "adopt a policy that establishes disciplinary actions

. . . that the institution will take if the board of trustees determines . . . that a tenured faculty member has failed to meet one (1) or more of the criteria described in" section 2(a). Id. § 21-39.5-2-2(d). Such disciplinary measures may include "(1) termination; (2) demotion; (3) salary reduction; (4) other disciplinary action as determined by the institutions; or (5) any combination" thereof. Id. § 21-39.5-2-2(d).

II. The Professors A. Professor Steven Alan Carr Steven Alan Carr ("Mr. Carr") is a professor of Communication, the Graduate Pro- gram Director of the Department of Communication, and the Director of the Institute for Holocaust and Genocide Studies (the "Institute") at Purdue University Fort Wayne

("PFW"). He began teaching at PFW in 1994 and was awarded tenure in 2000. In 2016, Mr. Carr was promoted to full professor status. As a professor of Communication, Mr. Carr teaches courses in media and cultural studies, and, as the Graduate Program Director, he advises approximately twenty graduate students. In his role at the Institute, he supports and promotes instruction and research about the Holocaust and other genocides as well as public engagement in global genocide pre-

vention efforts. In the upcoming 2024–25 academic year, Mr. Carr is scheduled to teach four courses: Introduction to Graduate Studies in Communication; Women, Men and Media; Documentary and Experimental Film and Video; and Mass Media Criticism. B. Professor David F. Schuster David Schuster ("Mr. Schuster") is an associate professor in PFW's Department of

History. He began teaching at PFW in 2006 and was awarded tenure in 2012. Although he intends to continue in his current position, he is also seeking a promotion to full professor- ship. In the upcoming academic year, Mr. Schuster is scheduled to teach the following history courses: American History I; American History II; U.S. History since World War

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