Wieland v. Board of Regents of the Nevada System of Higher Education

CourtDistrict Court, D. Nevada
DecidedFebruary 16, 2023
Docket3:19-cv-00724
StatusUnknown

This text of Wieland v. Board of Regents of the Nevada System of Higher Education (Wieland v. Board of Regents of the Nevada System of Higher Education) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wieland v. Board of Regents of the Nevada System of Higher Education, (D. Nev. 2023).

Opinion

3 UNITED STATES DISTRICT COURT

4 DISTRICT OF NEVADA

5 * * *

6 ALICE WIELAND, Case No. 3:19-cv-00724-MMD-CLB

7 Plaintiff, ORDER 8

9 v.

10 BOARD OF REGENTS OF THE NEVADA SYSTEM OF HIGHER EDUCATION, 11 Defendant. 12

13 I. SUMMARY 14 Plaintiff Alice Wieland brings this employment discrimination and breach of 15 contract action against Defendant Board of Regents of the Nevada System of Higher 16 Education (“NSHE”) after it denied Wieland tenure at the University of Nevada, Reno 17 (“UNR”). Before the Court is Defendant’s motion for summary judgment. (ECF No. 97 18 (“Motion”).)1 As further explained below, the Court will grant Defendant’s Motion as to 19 Wieland’s Title VII gender discrimination claim and state-law claims (Claims 2, 6, 7, 8). 20 The Court will dismiss Wieland’s four remaining claims without prejudice because 21 Wieland has voluntarily withdrawn them in response to the Motion.2 (ECF No. 103 at 2.) 22

1The Court has reviewed Wieland’s response (ECF No. 103) and Defendant’s 23 reply (ECF No. 105).

24 2Wieland misnumbers her voluntarily withdrawn claims, but the Court understands that Wieland is voluntarily dismissing Claims 1, 3, 4, and 5. (ECF No. 103 at 2.) In its 25 reply, Defendant notes Wieland’s voluntary withdrawal and “requests that the Court dismiss these four claims.” (ECF No. 105 at 20.) A plaintiff may not voluntarily withdraw 26 claims after the defendant has filed a motion for summary judgment without first obtaining leave of the Court. Fed. R. Civ. P. 41(a)(1)(A)(i). Accordingly, the Court 27 construes Wieland’s response as a motion for voluntary dismissal, which the Court now grants. See Fed. R. Civ. P. 41(a)(2) (instructing the Court, in granting a plaintiff’s motion 28 for voluntarily withdrawal, to dismiss claims without prejudice unless the order states 1 II. BACKGROUND 2 The following facts are undisputed unless noted otherwise. 3 A. Defendant’s Tenure and Promotion Process at UNR 4 UNR is a member institution of NSHE, a governmental entity created under the 5 Nevada Constitution that, through its Board of Regents, governs and manages Nevada’s 6 public higher education institutions. (ECF Nos. 97 at 3, 97-1 at 4-5.) See also Nev. 7 Const. art. 11, § 4. The NSHE Code (“Code”)—Title II of the Board of Regents 8 Handbook—“establish[es] the primary organizational structure” of NSHE and its member 9 institutions and “the basic personnel policies for its faculty.” (ECF No. 97-1 at 5.) The 10 Code governs the tenure and promotion process for tenure-eligible faculty and is 11 incorporated by reference in faculty employment contracts. (ECF Nos. 97-2 at 2, 104-1 12 at 2.) As such, the Code’s standards and procedures for tenure and promotion govern 13 faculty employment contracts “exclusive of any bylaws or other policies.” (Id.) 14 To gain promotion with tenure, a tenure-eligible professor must first submit an 15 application for appointment with tenure (“Tenure File”) near the end of a “probationary 16 period” of up to seven years. (ECF No. 97-1 at 15-17.) Under UNR’s bylaws and rules, 17 which supplement and augment the Code, a professor’s Tenure File is generally first 18 reviewed by a personnel committee within that professor’s department. (Id. at 17, 19.) 19 The reviewing personnel committee and department chair then issue their respective 20 tenure recommendations to the president of the NSHE institution (e.g., UNR). (Id. at 17.) 21 Once the university president receives the department’s recommendation in favor of 22 tenure, all “recommendations for appointment with tenure shall be made by the president 23 to the Board of Regents,” which “has final authority in making the appointment with 24 tenure” through an “affirmative majority vote.” (Id.) 25

26 otherwise). Because “[t]he decision to grant a voluntary dismissal under Rule 41(a)(2) is addressed to the sound discretion of the District Court,” the Court grants Wieland’s 27 motion for voluntary dismissal and dismisses without prejudice Claims 1, 3, 4, and 5. Hamilton v. Firestone Tire & Rubber Co., Inc., 679 F.2d 143, 145 (9th Cir. 1982). 28 1 The Code also prescribes specific tenure and promotion standards that a 2 professor’s reviewing committee and supervisors must apply to her Tenure File. These 3 three standards are teaching, research, and service. (Id. at 17-19.) “The major objectives 4 of tenure are to provide a faculty committed to excellence and to provide a substantial 5 degree of security to those persons who have exhibited excellent abilities, sufficient to 6 convince the University of Nevada community that their expected services and 7 performances in the future justify the privileges afforded by tenure.” (Id. at 14.) Tenure 8 and promotion decisions also advance broader social policies in higher education, such 9 as “community engaged teaching,” “research, scholarly, creative, or entrepreneurial 10 activity,” as well as commitments to “the best interests of the academic community” and 11 to “community engaged interaction with industry, business, government, and other 12 institutions of our society.” (Id. at 17-18.) 13 To be eligible for a recommendation for tenure, a professor must receive an 14 “excellent” rating from her peers and supervisors in at least one of the two core 15 standards—teaching and research—and a rating of “satisfactory” or higher in the other of 16 the two core standards. (Id. at 17.) Reviewers and recommenders typically consider 17 several sources and factors in evaluating an applicant’s performance, including annual 18 departmental reviews, external review letters, and student course evaluations. If an 19 applicant satisfies these standards, the reviewing committee and department chair 20 recommend either granting or denying tenure to the university president, who in turn 21 makes his own tenure recommendation to the Board of Regents. (Id.) Notably, a 22 professor’s eligibility for tenure under these standards, alone, does not guarantee the 23 ultimate approval of tenure and promotion; such decisions remain discretionary and 24 subject to multiple levels of approval. (Id.) 25 If a professor receives a recommendation against—that is, denying—tenure and 26 promotion, then that professor may request reconsideration. (Id. at 24.) The professor 27 must make the request to the department chair, supervisor, or college dean who 28 rendered the negative decision “with the reasons, arguments and documentation 1 supporting the request for reconsideration.” (Id.) The university president makes the final 2 decision on the professor’s reconsideration request unless the president changes her 3 mind and recommends appointment with tenure. (Id.) If that is the case, then the Board 4 of Regents, who has the final say, must nevertheless approve the recommendation. (Id.) 5 B. Wieland’s Employment and Performance at UNR 6 Wieland was a tenure-eligible assistant professor in the Managerial Sciences 7 Department of UNR’s College of Business from July 2012 until June 30, 2019. (ECF No. 8 103 at 2.) While a professor, Wieland’s workload was structured as a “40/40/20” role, 9 with 40% of her workload devoted to research, 40% devoted to teaching, and 20% 10 devoted to service. (ECF No. 97-12 at 2.) Wieland received annual departmental reviews 11 of her research and teaching performance. In her third-year review, in 2015, the 12 departmental personnel committee identified Wieland’s teaching weaknesses and 13 encouraged Wieland to “continue improving her teaching,” but concluded it was 14 “cautiously optimistic” about Wieland’s progress toward promotion and tenure. (ECF No.

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Wieland v. Board of Regents of the Nevada System of Higher Education, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wieland-v-board-of-regents-of-the-nevada-system-of-higher-education-nvd-2023.