In the

United States Court of Appeals

For the Seventh Circuit

No. 00-3395

Mary Anne Hedrich,

Plaintiff-Appellant,

v.

Board of Regents of the University

of Wisconsin System, et al.,

Defendants-Appellees.

Appeal from the United States District Court 

for the Western District of Wisconsin.

No. 99-C-719-C--Barbara B. Crabb, Chief Judge. 

Argued April 4, 2001--Decided December 19, 2001

 Before Coffey, Manion, and Diane P. Wood,

Circuit Judges.

 Diane P. Wood, Circuit Judge. Mary Anne

Hedrich was an assistant professor in the

Department of Health, Physical Education,

Recreation and Coaching at the University

of Wisconsin at Whitewater (the

University). She was unsuccessful in her

effort to be awarded tenure, however, and

she eventually filed this suit alleging

violations of state and federal law. The

district court ultimately dismissed all

of her theories either under Rule

12(b)(6) or on summary judgment. Hedrich

appeals only the court’s rulings on her

Title VII, equal protection, and liberty

interest in future employment counts. For

the reasons that follow, we affirm. 

I

 Given the procedural route the case took

in reaching this court, we take the facts

in a light favorable to Hedrich. For

those parts of the case that were

dismissed under Rule 12(b)(6), this means

that we ask whether any set of facts

consistent with her complaint could be

presented that would entitle her to

relief; for those parts that were

dismissed on summary judgment, the

question is whether the facts before the

court, taken in the light most favorable

to Hedrich, would permit a reasonable
finder of fact to rule in her favor. In

addition, for the summary judgment

portion of the case we must first

consider which facts were properly before

the court. Rule 56(c) of the Federal

Rules of Civil Procedure says that

summary judgment is proper if "the

pleadings, depositions, answers to

interrogatories, and admissions on file,

together with the affidavits, if any"

show that there are no genuine issues of

material fact and that the moving party

is entitled to judgment on the law. In

order to facilitate the court’s

consideration of supporting materials,

however, most district courts have

enacted local rules to impose some

structure on the process. Here, Hedrich

failed to follow those rules, and she may

have paid a price for that. (We say "may"

only because it is not at all clear that

the court’s enforcement of the local

rules made any difference to the ultimate

outcome; on the outside chance that it

did, we have considered Hedrich’s

arguments on this part of the case.)

 Once the University filed its motion for

summary judgment, along with its

supporting materials, it was up to

Hedrich to show why genuine issues of

material fact remained in the case.

Although Hedrich did file a response to

the University’s motion, the court found

fatal flaws in her "Response to

Defendants’ Proposed Findings of Fact and

Conclusions of Law" and her "Proposed

Additional Findings of Fact." Because

both of these filings violated the

court’s local summary judgment procedures

in significant respects, the court

decided to disregard much of Hedrich’s

evidence and to treat as admitted many of

the defendants’ factual propositions.

Hedrich contends that this action was an

abuse of discretion, because her

transgressions were merely technical. Our

review of the record convinces us that

Hedrich did indeed violate the local

rules and that the court was within its

discretion to impose the sanctions it

did.

 The district court found two principal

problems with the response and proposed

additional facts: first, they violated

Western District of Wisconsin Local Rules

I.C.2 and II.C.4, which require that

 factual propositions shall be set

forth in numbered paragraphs, and to the
extent practicable, each paragraph shall

state only one factual proposition ; and

second, they failed to cite with

specificity admissible evidence in

support of the factual propositions she

advanced. We agree. The purpose of the

"numbered paragraphs" rule is to permit

the district court to correlate factual

propositions with the admissible evidence

the party alleges supports her position.

Hedrich’s submissions did no such thing.

Instead, she repeatedly offered long

strings of factual propositions in single

paragraphs that in some cases stretched

on for pages. In some instances, these

paragraphs did not even cast doubt on the

defendants’ proposed facts. Hedrich takes

issue with the court’s criticism of her

citations, but again, she misses the

point. While she literally provided

citations, they were not in the form

called for by the rule and they did not

serve the purpose of the rule. Instead,

they tended to be string citations at the

end of paragraphs containing numerous

factual propositions, again often

stretching over more than one page. In

several instances she concluded a factual

statement with only a cross- citation to

another fact paragraph that was itself

pages long and improperly supported.

These citations provided the court no

guidance as to which factual propositions

could be located where in the record. Not

only were these real offense[s] against

the local rules, it is precisely to

prevent this type of rambling summary

judgment submission that such rules

exist. Markham v. White, 172 F.3d 486,

490 (7th Cir. 1999) (explaining that

strict enforcement of local rules is

necessary to allow the court to organize

the evidence and identify undisputed

facts). 

 In light of these problems, we cannot

say that the district court abused its

discretion by choosing an unduly harsh

sanction. To the contrary, it is common

to punish a party’s failure to comply

with summary judgment rules by ignoring

that party’s unsupported factual

allegations and accepting as true those

of the opposing party. See, e.g., Midwest

Imports, Ltd. v. Coval, 71 F.3d 1311,

1313 (7th Cir. 1995) (failure to properly

contest factual assertions under local

rules constitutes binding admission of

those facts); Bordelon v. Chicago Sch.

Reform Bd. of Trs., 233 F.3d 524 (7th
Cir. 2000) (exclusion not too harsh where

submissions undermine purpose of local

rules). In this case, both the local

rules and a separate reminder that the

court issued to the parties left no

question that the court would consider

only evidence that was set forth in a

proposed finding of fact with the proper

citation. Hedrich does not claim that she

was unaware of the rules or that the

rules were not clear, nor does she offer

any reasonable excuse for not complying

with them. Under the circumstances, the

sanction of exclusion was within the

district court’s discretion. Waldridge v.

American Hoechst Corp., 24 F.3d 918,

921-22 (7th Cir. 1994) (collecting cases

where strict enforcement of local summary

judgment rules has been upheld). Finally,

we do not find the district court’s

rulings too opaque to follow for purposes

of appellate review. We thus consider

this appeal on the basis of the record

the district court found to be properly

before it.

II

 Hedrich was hired by the University in

1990 as a tenure-track faculty member of

the Department of Health, Physical

Education, Recreation and Coaching (the

Department). When she joined the

Department, the majority of the tenured

faculty was female, but it also included

some men, including Dr. Steven

Albrechtsen. Years earlier, Albrechtsen

had filed a sex discrimination claim

against the University after it failed to

promote him. Hedrich and Albrechtsen

became friends.

 In the late fall of 1995, Hedrich came

up for tenure. At that time, the

chairperson of the Department was James

Miller. Defendant Brenda Clayton (also a

tenured faculty member in the Department)

succeeded him as chairperson in July

1996. Defendant H. Gaylon Greenhill was

Chancellor of the University, defendant

Kay Schallenkamp was Provost, and

defendant Jeffrey Barnett was Dean of the

College of Education (to which the

Department belonged).

 The tenured faculty in the Department

met December 4, 8, and 18 of 1995 to

review Hedrich’s tenure file, which

included materials related to her

teaching (peer and student evaluations),
her scholarship (research,

publications,presentations at

professional associations), and her

service and committee work for the

University. Hedrich made an oral

presentation to the committee on December

4, 1995. The committee ultimately rated

Hedrich above average in teaching and

service, but it gave her a below average

rating for scholarly activity. Hedrich

had submitted four manuscripts to

national peer-reviewed journals for

consideration, but none had yet been

accepted for publication. At the time of

the review, Hedrich had no publications

to her credit despite the fact that

Barnett had told her in two previous

performance reviews that this would be a

critical factor in her tenure decision.

The committee voted 7 to 1 to deny

Hedrich tenure. Only Albrechtsen voted in

Hedrich’s favor.

 Miller reported the committee’s decision

to Dean Barnett and Chancellor Greenhill,

explaining that the committee had

discussed Hedrich’s research and

scholarly activity at length but found

the four unpublished manuscripts to be

insufficient to demonstrate the requisite

degree of scholarly achievement. Barnett,

in a memorandum to Chancellor Greenhill

dated January 16, 1996, concurred in the

committee’s recommendation. That

memorandum noted that Hedrich had failed

to submit documentation of her teaching,

research, and service achievements to the

faculty committee. Barnett also noted the

insufficiency of Hedrich’s four

unpublished manuscripts.

 Hedrich received notice of the faculty

committee’s decision on January 16, 1996.

On January 25, 1996, she received a

letter from Provost Schellenkamp telling

her that the 1996-97 academic year would

be her last. Hedrich immediately sought

an explanation from Miller for the

decision and he cited her low rating for

scholarly activity. Hedrich requested

reconsideration by the faculty, but after

two meetings the faculty reconfirmed its

decision. Hedrich then appealed to the

Faculty Grievance and Hearing Committee,

which convened the Hedrich Tenure Review

Appeals Panel (Appeals Panel).

 The Appeals Panel, headed by Dr. Douglas

Eamon, eventually issued a report to

defendants Greenhill and Barnett on June
14, 1996. The report concluded that, con

trary to Barnett’s claim to Greenhill in

his January 16 memorandum, there was no

problem with the documentation Hedrich

had submitted to the faculty committee

about her scholarly, teaching, and

service activities. It also concluded

that the Department faculty committee’s

decision to deny tenure on the basis of

Hedrich’s having failed to publish any of

her manuscripts in nationally peerreviewed journals was not consistent

with the performance criteria adopted by

the department and stated in the

University Handbook. Although the panel

did not say so, it believed that this

conclusion would require the empaneling

of a so-called Notestein Review

Committee. 

 Wisconsin law provides that tenure may

be granted only where the Board of

Regents receives an affirmative

recommendation from the faculty member’s

department and from the university

chancellor, unless a tenure appeals panel

concludes that the department based its

decision to deny tenure on impermissible

factors. Wis. Stat. sec. 36.13(2)(a). In

that case, an independent committee--

called a Notestein committee, after the

state Assembly member who initiated the

legislation creating these procedures--

may be convened to conduct an independent

assessment of the candidate’s

qualifications. If that committee

determines that the faculty member should

receive tenure and the chancellor makes

an affirmative recommendation to that

effect, then the Board of Regents may

grant tenure over the objection of the

faculty member’s department. Wis. Stat. 

36.13(2)(b). One impermissible factor

that may trigger a Notestein committee is

the improper consideration of

qualifications, such as the failure to

consider available data bearing

materially on the quality of

performance. Wis. Admin. Code sec. UWS

3.08(1)(c). 

 When Greenhill received the Appeals

Panel report, he decided that its

findings did not warrant empaneling a

Notestein committee. As Greenhill

understood the system, the Wisconsin

Administrative Code gives the chancellor

the final say over how to proceed with an

appellate panel’s findings. See Wis.

Admin. Code sec. UWS 3.08(3) ("The
decision of the chancellor shall be final

on such matters"). In a June 28, 1996,

memorandum, Greenhill reported to the Ap

peals Panel, the Department, and to

Hedrich that after reviewing the panel’s

report he saw no basis for convening a

Notestein committee. Greenhill found

nothing in the report to indicate that

the Department had relied on

impermissible factors in reaching its

decision. He also concluded that Hedrich

had not presented clear evidence that she

met the scholarship requirements for

tenure and affirmed the Department’s

decision.

 Eamon, now joined by Richard Schauer,

Chair of the Academic Freedom and Tenure

Committee, strenuously objected to

Greenhill’s decision not to convene a

Notestein committee. Their dispute turned

on the proper interpretation of the

Wisconsin statutes and administrative

code. On October 25, 1996, after a series

of memoranda failed to persuade

Greenhill, the Appeals Panel amended 

its earlier report, explicitly finding

that the Department had relied on

impermissible factors in denying Hedrich

tenure. Upon receiving the amended

findings, Greenhill initially relented

and agreed to return the matter to the

Department for reconsideration.

 The Department’s tenured faculty, now

led by defendant Clayton, objected to

Greenhill’s decision. They sent the

Chancellor a letter in which they argued

that Hedrich’s request was not timely and

that she had not demonstrated any rule

violations in the tenure denial process.

Ultimately, Greenhill agreed. In a

November 22, 1996, memorandum to all

parties involved, he explained that the

appeals process was concluded and that

the matter [of Hedrich’s tenure] must

now be considered closed. He cited his

June 28, 1996, letter as the legally

determinative final judgment in the

matter.

 Eamon and Schauer again challenged

Greenhill’s authority to close the matter

without convening a Notestein committee.

On January 17, 1997, with their support,

Hedrich asked the Faculty Senate

Executive Committee to commence a

Notestein review. The Executive Committee

agreed to convene an ad hoc credential

review committee, over Greenhill’s
strenuous objection, in the Spring of

1997. The Hedrich Credential Review

Committee (CRC) considered the materials

relevant to Hedrich’s tenure that were

before the Department at the time of its

initial decision. On November 5, 1997,

the CRC concluded that Hedrich had

properly been denied tenure. Believing

that the CRC had not followed proper

procedures when considering her record,

Hedrich appealed its decision to the

Executive Committee of the Faculty

Senate. The Executive Committee has not

acted on the matter.

 Hedrich began looking for alternative

academic employment in the Spring of

1997. She applied for two positions that

year. She applied for one position in the

spring of 1998 and two that fall.

Finally, she applied for two positions in

1999. All her applications were without

success. Hedrich ultimately took a

position as a staff nurse in Pewaukee,

Wisconsin.

 On September 1, 1998, Hedrich filed a

complaint with the Wisconsin Personnel

Commission (WPC) alleging gender, age,

and sexual orientation discrimination.

The WPC dismissed her complaint as not

timely. It concluded that Hedrich did not

file her charge until more than 300 days

after any reasonable person would have

known that her tenure application had

been denied. Later in September of 1998,

Hedrich filed the same charges with the

EEOC. The EEOC also dismissed her

complaint as untimely.

 Hedrich then filed suit in Wisconsin

state court. The defendants removed the

case to federal court. Hedrich’s

complaint alleged several violations of

law. She alleged that defendants

discriminated against her on the basis of

"gender, sexual orientation, and age" in

violation of 42 U.S.C. sec. 2000 et seq.

and 29 U.S.C. sec. 623 et seq., and that

defendants deprived her of her

"constitutionally protected liberty

interest in her good name and reputation

without due process of law." The district

court also construed Hedrich’s complaint

as stating an equal protection claim.

Defendants filed motions to dismiss on

the pleadings and on summary judgment;

they succeeded in their effort to win

summary judgment. Hedrich now appeals all

adverse rulings except the one dismissing
the age discrimination theory.

III

A. Title VII 

 Hedrich’s theory of sex discrimination

in her unsuccessful bid for tenure rests

on the idea that the defendants were

motivated by her association with a male

employee who had earlier filed a sex

discrimination claim against the

University, Dr. Albrechtsen. In support

of her associational discrimination 

theory, Hedrich cites Drake v. Minnesota

Mining & Mfg. Co., 134 F.3d 878 (7th Cir.

1998) and Moffett v. Gene B. Glick Co.,

621 F.Supp. 244 (N.D. Ind. 1985). We need

not decide whether this is really a sex

discrimination theory, if it is really a

retaliation theory, or if there was

adequate factual support for it either

way, because Hedrich’s complaint to the

WPC was filed too late.

 Hedrich had 300 days from the time she

suffered her adverse employment action--

the denial of tenure--to file her

complaint with the WPC or the EEOC. See

Alexander v. Wisconsin Department of

Health and Family Services, 263 F.3d 673,

680 n.1 (7th Cir. 2001); 42 U.S.C. 

2000e-5(e). She filed her complaint with

the WPC on September 1, 1998, meaning

that her adverse employment action was

actionable only if it occurred on or

after November 5, 1997. Because under

Wisconsin law the Board of Regents may

grant tenure only when it has an

affirmative recommendation from a

university chancellor, the district court

concluded that Hedrich should have known

no later than her receipt of Greenhill’s

June 28, 1996, memorandum that her tenure

application had been denied. Citing the

Supreme Court’s opinion in Delaware State

College v. Ricks, 449 U.S. 250 (1980),

the court found that the mere fact that

Hedrich had avenues available (or created

avenues) to appeal Greenhill’s decision

did not alter the fact that his decision

was final for purposes of the limitations

period on her Title VII claim. As the

Supreme Court put it in Ricks,

 entertaining a grievance complaining of

the tenure decision does not suggest that

the earlier decision was in any respect

tentative. 449 U.S. 505-06. While it is

also possible that Greenhill’s decision

was not final until his memorandum of
November 26, 1996, in which he declared

the Hedrich tenure matter to be closed, 

that date is also far too early to be

included within Hedrich’s Title VII

complaint. 

 Despite Hedrich’s tardy filing, the

district court declined to dismiss

Hedrich’s Title VII claim on timeliness

grounds. It found that she had made a

 plausible assertion of estoppel. We

think this conclusion cannot be squared

with Ricks. In order to make out a claim

for equitable estoppel, the plaintiff

must present evidence that the defendant

[took] active steps to prevent the

plaintiff from suing in time. Hentosh v.

Herman Finch Univ., 167 F.3d 1170, 1174

(7th Cir. 1999). These steps must amount

to "a deliberate design by the employer

or . . . actions that the employer should

unmistakably have understood would cause

the employee to delay filing his charge."

Mull v. ARCO Durethene Plastics, Inc.,

784 F.2d 284, 292 (7th Cir. 1986). They

are typically acts of wrongdoing such

as hiding evidence or promising not to

rely on a statute of limitations defense.

Cada v. Baxter Healthcare Corp., 920 F.2d

446, 450-51 (7th Cir. 1990). In this

case, the only steps taken by the Univer

sity after June 28, 1996, were those

initiated by Hedrich in her effort to

appeal Greenhill’s decision. No

reasonable jury could conclude that these

were acts of wrongdoing undertaken by the

University to dissuade Hedrich from

filing a Title VII claim. Moreover, if

permitting Hedrich to appeal the

Chancellor’s concededly final tenure

decision was a step to prevent plaintiff

from suing in time, then any time a

faculty member took advantage of an

opportunity to appeal an adverse tenure

decision within her university system the

Title VII statute of limitations would be

tolled. This is exactly the proposition

that was proposed and expressly rejected

in Ricks. 449 U.S. at 261.

 Other than permitting Hedrich to invoke

the University system’s internal appeals

procedure, none of the defendants in this

case did anything to suggest to her that

Greenhill’s June 28, 1996, decision and

his emphatic affirmation of that decision

in November of 1996 were anything other

than final. Although the question of when

a tenure decision becomes final for Title

VII purposes can be a difficult one, it
is not a problem here. The only question

is whether permitting a tenure applicant

to pursue avenues of appeal after a final

adverse tenure decision is enough to

raise a triable issue of equitable

estoppel. It is not. This leaves us with

our earlier conclusion: Hedrich’s Title

VII claim was not timely filed and was

thus properly dismissed.

B. Equal Protection Violation

 Hedrich also raised two claims under 42

U.S.C. sec. 1983: the first was an equal

protection claim, which she brought

against only the individually named

defendants and not the Board of Regents,

in which she asserted that the process by

which her tenure decision was made

constituted a denial of her rights under

the Equal Protection Clause; the second

was a due process claim (also against

only the individuals), which we address

below. The district court offered

tworeasons for dismissing the equal

protection claim: first, that Hedrich had

not adequately alleged that a conspiracy

existed between the named defendants, and

second, that she failed to present

sufficient evidence of an equal

protection violation to survive summary

judgment because she had adduced no

evidence to show that she was

treateddifferently from any other

similarly situated candidate or that the

defendants were motivated by the intent

to discriminate against persons such as

plaintiff. We affirm on the basis of the

second of these reasons.

 There is no dispute that part of

Hedrich’s employment contract with the

University included a promise by the Uni

versity to consider her for tenure. And

we agree that the process by which her

tenure application was decided is subject

to scrutiny under the equal protection

clause. See, e.g., Gregory v. Ashcroft,

501 U.S. 452 (1991) (considering whether

mandatory retirement age for judges

violates the Equal Protection Clause). In

order to make out an equal protection

claim, however, Hedrich had to present

evidence that the defendants treated her

differently from others who were

similarly situated. She also had to

present evidence that the defendants

intentionally treated her differently

because of her membership in the class to

which she belonged. See Personnel Adm’r
of Mass. v. Feeney, 442 U.S. 256, 279

(1979); Nabozny v. Podlesny, 92 F.3d 446,

453 (7th Cir. 1996). Finally, where, as

here, Hedrich alleges that she was a

class of one --a heterosexual female

professor who befriended Dr. Albrechtsen,

a heterosexual male professor who had

previously filed a sex discrimination

complaint--it was her burden to show that

the defendants justification for

discriminating against her was irrational

and arbitrary. Village of Willowbrook v.

Olech, 528 U.S. 562, 564 (2000). 

 We agree with the district court that

Hedrich did not present competent

evidence on several of these elements. In

particular, while she offered evidence

that the criteria the faculty applied in

assessing her scholarship were not

consistent with those set out in the

University Handbook, she had nothing to

indicate that other tenure applicants in

the Department were not assessed

according to the same allegedly erroneous

criteria. Hedrich also failed properly to

present any evidence to support her claim

that the real reason that each of the

defendants acted to deny her tenure was

to punish her for her friendship with Dr.

Albrechtsen. To the contrary, the record

reveals that male and female faculty

members alike (including the male

chairperson) voted to deny her tenure,

and she has no theory to explain why the

male members might have resented the

heterosexual friendship. With no evidence

on these two critical points, the court

properly dismissed Hedrich’s equal

protection claim.

C. Liberty Interest

 Hedrich last contends that the

defendants actions in denying her tenure

deprived her of her liberty interest in

pursuing her chosen career, in violation

of her due process rights. As we

explained recently, if the character

and circumstances of a public employer’s

. . . conduct or statements are such as

to have destroyed an employee’s freedom

to take advantage of other employment

opportunities, the employee can bring

suit based on the deprivation of his

freedom to pursue the occupation of his

choice. Bordelon, 233 F.3d at 531.

 In order to reach a jury on her liberty

interest claim, Hedrich first had to

present evidence that the defendants
engaged in conduct that was so

stigmatizing that it crossed the line

from mere defamation, which is not

actionable under the Constitution, see

Paul v. Davis, 424 U.S 693, 701 (1976),

over to an infringement of a liberty

interest. The denial of tenure or

employment is not, by itself,

stigmatizing conduct in the legal sense

of the term. Wooten v. Clifton Forge

School Bd., 655 F.2d 552, 555 (4th Cir.

1981) (no liberty interest claim arises

merely from denial of tenure). As we

explained in Lawson v. Sheriff of

Tippecanoe County, 725 F.2d 1136, 1138-39

(7th Cir. 1984), a termination is only

stigmatizing if it is accompanied by a

publicly announced reason that impugns

[the employee’s] moral character," id. at

1138, or implies "dishonesty or other

job- related moral turpitude id. at

1139. See also Board of Regents of State

Colleges v. Roth, 408 U.S. 564, 573

(1972).

 Hedrich urges that she was stigmatized

by the defendants statements that she

did not meet Whitewater’s standards of

scholarship. This inference can be drawn,

however, from practically every denial of

tenure or termination. Labeling an

employee as incompetent or otherwise

unable to meet an employer’s expectations

does not infringe the employee’s

liberty. Head v. Chicago Sch. Reform Bd.

of Trustees, 225 F.3d 794, 801 (7th Cir.

2000). Alternatively, Hedrich contends

that she was stigmatized by the

defendants claims that she did not

submit the relevant documentation for

consideration by the faculty. This, she

argues, portrays her to be a dolt. The

district court found that no properly

presented evidence could support the

proposition that the defendants’

statements were false. See Strasburger v.

Board of Education, 143 F.3d 351, 356

(7th Cir. 1998). Even assuming that

Hedrich did present such evidence,

however, these statements do not suggest

the kind of moral turpitude or dishonesty

that would give rise to a liberty

interest claim.

 If Hedrich could identify stigmatizing

statements made by her employer, she

would then have to provide evidence that

these were made public and that as a

result it was virtually impossible for

[her] to find new employment in [her]
chosen field. Head, 225 F.3d at 801.

Hedrich cannot satisfy either of these

requirements. The only evidence she

points to is the fact that over three

years she applied for seven academic jobs

and was not hired. From this she believes

that a reasonable jury could infer that

the defendants were publicly defaming her

and that it was virtually impossible for

her to find an academic position. Anyone

familiar with the academic job market

knows that failing to receive a tenure

track position after only seven

applications is commonplace, even under

the best of circumstances. There is also

no question that once a person has been

denied tenure, finding another academic

position is considerably more difficult;

failing on seven attempts in that case is

not surprising. Nonetheless, Hedrich’s

evidence could not be construed by a

trier of fact to show that the

consequences of her tenure denial have

been any more severe than any other

professional’s failure to receive a

desired promotion. Hedrich’s liberty

interest claim was properly denied.

IV

 We recognize that the denial of tenure

is a serious matter for someone who is

trying to pursue an academic career. It

is possible--though we express no opinion

on the point-- that Hedrich’s tenure

application could have been handled

better. The University may have lost a

quality faculty member. But on the record

before us, no reasonable jury could

conclude that Hedrich’s denial of tenure

violated her rights under federal law. We

therefore Affirm.