IN THE COURT OF APPEALS OF IOWA

No. 13-1628

Filed November 26, 2014

MALIK JUWEID,

Petitioner-Appellant,

vs.

IOWA BOARD OF REGENTS, et al.,

Respondent-Appellee.

________________________________________________________________

Appeal from the Iowa District Court for Polk County, Robert J. Blink, 

Judge.

Malik Juweid appeals the district court’s ruling on judicial review that

concluded he was not denied due process in the administrative proceedings. 

AFFIRMED. 

Rockne O. Cole of Cole & Vondra, PC, Iowa City, for appellant.

Thomas J. Miller, Attorney General, and George A. Carroll, Assistant 

Attorney General, for appellee State.

Heard by Danilson, C.J., and Doyle and Tabor, JJ.
2

DANILSON, C.J.

Malik Juweid appeals the district court’s ruling on judicial review that 

concluded he was not denied due process in the administrative proceedings. 

Juweid argues impermissible conflicts of interest denied him due process in the 

university disciplinary proceedings charging him with violations of its ethics and 

anti-harassment policies. He asserts University of Iowa President Sally Mason’s 

contemporaneous role as an intermediate decision maker in university 

disciplinary proceedings and as a defendant in Juweid’s civil suit against her 

constituted actual bias. He also maintains the assistant attorney general’s role 

as legal advisor to the university in both proceedings was impermissible. 

Juweid’s claims he was denied due process as a result of conflicts of 

interest fail because he has neither overcome the presumption of honesty and 

integrity to which President Mason and Assistant Attorney General Carroll are 

entitled nor established actual conflicts of interest.

I. Background Facts and Proceedings.

Juweid was a tenured faculty member at the University of Iowa, Carver 

College of Medicine. He has published articles asserting the dangers of 

excessive use of PET-CT scans, particularly in children. One such article was 

published in March 2010. During the fall and summer of 2010, Juweid

recommended reduction of what he considered excessive imaging at University 

of Iowa Hospitals and Clinics (UIHC). On October 28, 2010, he sent President 

Mason an email criticizing UIHC for failing to implement his recommendations

and asking for an investigation of the overuse of imaging in children. 
3

On January 12, 2011, University of Iowa Provost Tom Rice placed Juweid 

on administrative leave upon advice of the university’s threat assessment team.

1

On February 11, 2011, pursuant to provisions of the university’s 

operations manual, Rice sent Juweid a written “Ethics Complaint—Notice of 

Charges” (hereinafter complaint). The complaint detailed twenty-eight instances 

of statements made in emails Juweid sent to numerous coworkers and university 

officials between February 8, 2010, and February 9, 2011, which allegedly 

“disparaged and attacked the character and integrity of colleagues at the 

University and other institutions” in violation of section 15.4 of the operations 

manual. That provision states in part, “In the exchange of criticism and ideas, 

[the faculty member] shows due respect for the rights of others to their opinion. 

He or she refrains from personal vilification . . . .” The complaint indicated 

Juweid “violated Section 15.4 by sending numerous prejudiced, insulting and 

inflammatory emails to colleagues,” one of which was an October 27, 2010 

email2to President Mason and others,

under the subject line “NPR Fires Analyst for Saying Muslims Make 

Him Nervous—And what Does the University of Iowa Do?” You 

[Juweid] accused Gay Pelzer of defending Dr. Fajardo [the 

chairperson of the radiology department] whom you allege as 

having made comments that are anti-gay, anti-Arab, discriminatory 

to minorities and religious practices and retaliatory. You accuse 

University administration of retaliation and discrimination and state 

that it is “time to react, Dr. Mason, before this all hits the press, the 

Iowa and Federal Civil Rights Commissions, the Federal Equal 

Opportunity and Diversity office, the Arab-American AntiDiscrimination committee and other civil rights committees.”

 

1 Nothing in this record indicates any investigation of Juweid’s conduct was instigated by 

President Mason.

2 There is no evidence in this record as to whether President Mason read this email. 
4

The complaint asserted Juweid’s remarks in the numerous, listed emails—

as well as his “abusive tone”—were “unprofessional, unnecessary, and 

embarrassing to yourself and the University.” The complaint also cited a 

September 2008 agreement reached between Juweid and the then-associate 

provost in which Juweid promised not to communicate with colleagues using 

“racially pejorative terms in reference to the recipients.” The February 2011 

complaint indicated additional complaints about Juweid’s workplace conduct 

were being investigated. Copies of the complaint were sent to the presiding 

officer of the faculty judicial commission, the vice president for medical affairs, 

the interim executive vice president and provost, the dean of the college of 

medicine, and the head of the radiology department. 

On February 15, 2011, on the recommendation of Lois Geist, the 

associate dean of faculty affairs of the university’s medical school, Rice filed 

disciplinary charges against Juweid alleging violation of the anti-harassment, 

disruptive behavior, and anti-retaliation policies of the university.

On April 22, 2011, academic investigator Linda McGuire recommended 

disciplinary proceedings continue on the anti-harassment and disruptive behavior 

grounds.

On May 6, 2011, Juweid filed a lawsuit against twenty-five defendants, 

including President Mason, alleging he was entitled to whistleblower protections 

and had been subjected to retaliation in violation of state and federal civil rights 

acts. (An amended petition was filed in August 2011.)

3

 In part, Juweid sought a 

 

3

Juweid voluntarily dismissed this lawsuit (CVCV073326) without prejudice on 

November 1, 2012.
5

temporary injunction staying the disciplinary process while the civil action was 

pending.

On May 12, 2011, Juweid was sent another disciplinary complaint, which 

gave notice of charges that included violations of the university’s antiharassment, disruptive behavior, and professional ethics and academic 

responsibility policies, as well as a violation of the Health Insurance Portability 

and Accountability Act (HIPAA) (concerning protected health information). Again, 

copies were sent to the presiding officer of the faculty judicial commission, the 

vice president for medical affairs, the interim executive vice president and 

provost, the dean of the college of medicine, and the head of the radiology 

department.

Following operations manual procedures, a three-person faculty panel 

presided over a June 15, 2012 hearing4on the charges stated in the two 

complaints. Juweid was allowed the assistance of counsel but chose to 

represent himself. The university was represented by Assistant Attorney General 

George Carroll. While Juweid’s argument refers to President Mason as a 

complaining witness, only three witnesses testified for the university: Dr. Geist,

the Associate Dean of Faculty Affairs, and Peter Berkson and Jane Caton, two 

members of the university threat assessment team. Juweid was afforded the 

opportunity to cross-examine the witnesses. He also had the opportunity to call 

witnesses and present documentary evidence.

On July 23, 2012, the panel issued unanimous findings, conclusions, and

recommendations. It found “clear and convincing evidence” that Juweid had 

 

4 Apparently, the hearing was continued numerous times for varying reasons.
6

repeatedly violated section 15.4 by failing to “avoid[] interference with [others’] 

work,” engaging in “personal vilification,” engaging in “threatening, intimidating, or

abusive language,” and engaging in “conduct that creates a hostile work 

environment.” The panel also found Juweid had violated HIPAA. The panel 

recommended Juweid be dismissed from his tenured faculty position in the 

department of radiology and his employment be terminated. 

On August 16, 2012, Juweid appealed the panel’s decision, which would 

normally go to the university president, Mason. However, Juweid sought an 

“external adjudicator”

due to the UI’s flagrant violation of his procedural and substantive 

due process rights in this termination proceeding. The obvious 

conflict is that your own [Mason’s] lawyer in our whistleblowing and 

civil rights lawsuit against you, George Carroll, is now submitting a 

brief to you, his client, asking you to determine that you did not 

retaliate against Dr. Juweid due to his whistleblowing activities. 

This is an obvious conflict of interest impairing Dr. Juweid’s rights to 

an impartial appeal process.

. . . .

. . . You are now subject of a civil action as to whether you 

violated Dr. Juweid’s rights under the Whistle Blower statute; 

Section 1983; and the 1st, 5th and 14th Amendments to the US 

Constitution. You cannot now possibly be called upon pass upon 

your own actions.

An “Academic Officer’s Brief to President Mason Following Panel’s 

Findings, Conclusions and Recommendations” was also submitted on August 16. 

It made no mention of the request for an external adjudicator.

On August 21, 2012, President Mason issued a letter stating, “I have 

reviewed the materials, findings and subsequent briefs filed in the matter of an 

Ethics Charge against Dr. Malik Juweid, and I accept the recommendations for

sanctions. I direct that the panel’s recommendations be implemented.”
7

On October 2, 2012, Juweid appealed to the Iowa Board of Regents,

challenging “all adverse factual findings and legal conclusions” of the panel’s 

decision. He also alleged he was denied due process because of impermissible 

conflicts of interest (1) on the part of the assistant attorney general who argued 

the appeal to President Mason and represented President Mason in Juweid’s 

civil action and (2) on President Mason’s part because she was a defendant in 

the civil action and was the adjudicator in the disciplinary proceedings. He asked 

for a stay of the disciplinary decision, reversal of President Mason’s decision, and 

the recusal of President Mason from considering his new agency administrative 

hearing.

The board of regents denied Juweid’s motion to stay proceedings, 

rejecting his claims of impermissible conflicts of interest. With respect to Mason, 

the board concluded: 

For the purposes of the administrative proceeding President Mason 

is presumed unbiased, and Dr. Juweid carries the burden of 

proving otherwise. Schweiker v. McClure, 456 U.S. 188, 195-96 

(1982). The simple fact that two proceedings are pending in two 

different forums is not, in and of itself, enough to establish bias. To 

find otherwise would permit an employee to interfere with 

established University disciplinary procedures simply by filing 

litigation against the decision-maker.

Addressing the claim as to the assistant attorney general, the board stated, 

Dr. Juweid has not demonstrated how Assistant Attorney General 

Carroll’s defense of President Mason in the civil matter adversely 

affected his representation of the University in the disciplinary 

matter. While it is true that the final institutional decision rested 

with President Mason, Dr. Juweid has failed to present evidence

tending to indicate that Assistant Attorney General Carroll’s 

representation improperly influenced her decision or that of the 

Faculty Judicial Panel.

 

On February 8, 2013, the board of regents denied Juweid’s appeal. 
8

Juweid then filed a petition for judicial review, again asserting the 

administrative procedures denied him of due process. While Juweid argued to 

the district court that President Mason was a “complaining witness” in the 

disciplinary proceeding, it was only in the sense that Juweid sent two emails to 

President Mason.

5 He contended that in order to bring a whistleblower action, he 

was required to “blow the whistle” to President Mason. The district court affirmed 

the agency action. Juweid appeals.

II. Scope and Standard of Review. 

Because constitutional issues are raised, our review is de novo. Botsko v. 

Davenport Civil Rights Comm’n, 774 N.W.2d 841, 844 (Iowa 2009). 

III. Discussion.

Juweid asserts he was denied a fair trial in a fair tribunal due to conflicts of 

interest existing with the assistant attorney general and the university president.

Our supreme court has most recently addressed the framework for 

procedural due process claims in administrative proceedings in Botsko, 774 

N.W.2d at 848-82. “A party in an administrative proceeding is entitled to 

procedural due process.” Id. at 848. Due process always involves a 

constitutional floor of a “fair trial in a fair tribunal.” Id. “[I]n some situations, such 

as those involving pecuniary interest or demonstrated personal bias, ‘experience 

teaches that the probability of actual bias on the part of the judge or 

 

5 Only the October 27, 2011 email was mentioned in the disciplinary complaint. Provost 

Rice described that email as “accus[ing] University administration of retaliation and 

discrimination and state that it is ‘time to react, Dr. Mason, before this all hits the press, 

the Iowa and Federal Civil Rights Commissions, the Federal Equal Opportunity and 

Diversity office, the Arab-American Anti-Discrimination committee and other civil rights 

committees.’”
9

decisionmaker is too high to be constitutionally tolerable.’” Id. (quoting Withrow 

v. Larkin, 421 U.S. 35, 47 (1975)).

“[T]he mere fact that investigative, prosecutorial, and adjudicative 

functions are combined within one agency does not give rise to a due process 

violation.” Id. at 849. “[T]here is a consensus in the case law that even where 

investigative and adjudicative functions are combined in a single individual or 

group of individuals, there is no due process violation based solely upon the 

overlapping investigatory and adjudicatory roles of agency actors.” Id. The 

Botsko court ruled, “In order to prove a procedural due process violation in the 

context of a combination of investigative and adjudicative roles, even in a single 

individual, the challenging party must bear the difficult burden of persuasion to 

overcome the presumption of honesty and integrity in those serving as 

adjudicators.” Id. at 849. 

Where, however, the same person within an agency performs both 

prosecutorial/advocacy and adjudicative roles, there may arise a “will to win,” 

which creates a risk that due process has been violated so great that the 

“ordinary requirement of actual bias or prejudice in separation of functions 

challenges does not apply.” See id. 

A. President Mason. Juweid contends President Mason was both 

accuser and witness in the disciplinary action, as well as a civil defendant, 

potential criminal defendant, and adjudicator in his disciplinary action. He 

contends President Mason’s impartiality to preside over his disciplinary 

proceedings “can reasonably be questioned” and he need not show actual bias 
10

or prejudice because the conditions here created a “will to win” on the part of 

President Mason.

We are not persuaded by Juweid’s attempts to fit the present 

circumstances into the exception to the general rule that he, as the challenging 

party, bears the burden of overcoming the presumption of honesty and integrity. 

See id. Juweid offers only bald assertions that President Mason was the “chief 

accuser/witness” in his disciplinary hearing,6that she had a pecuniary interest in 

the outcome of the civil suit,7and that the outcome of his civil action could 

subject President Mason to criminal liability.8 We reject these unsubstantiated 

claims and agree with the reasoning of the board of regents:

Dr. Juweid cites Gibson v. Berryhill, 411 U.S. 564 (1973), in 

support of his contention that President Mason was conflicted out of 

rendering a final institutional decision in his disciplinary matter. In 

Gibson, administrative action was initiated before the Alabama 

Board of Optometry challenging the licensure of a group of 

optometrists based on allegations related to the unlawful practice of 

optometry. 411 U.S. at 567. Prior to ruling, the Board of Optometry 

sued the individual optometrists and the company with whom they 

were associated citing the same issues that were raised in the 

administrative complaint. ld. at 568. Following a favorable ruling in 

district court, the Board of Optometry proceeded with the 

administrative complaint against the individual optometrists. Id.

The individual optometrists filed suit alleging, essentially, that the

Board could not act as a fair and impartial arbiter of the 

administrative complaint. Id. at 570.

The District Court considered two distinct sources of 

possible bias. Given that the Board previously initiated suit on the

 

6

Juweid points to his October 27, 2010 email to President Mason, which he claims 

“interjected President Mason as a witness in his disciplinary proceeding.” But the email 

was written by Juweid, not Mason. Mason was not called as a witness in the disciplinary 

proceeding. The two administrative complaints mention emails Juweid sent to Mason, 

but this hardly transforms Mason into the “chief accuser/witness.” 

7

Juweid cites 42 U.S.C. § 1983 in this regard, contending that because he sued Mason 

in her individual capacity, she was subject to personal liability, which in turn created a 

pecuniary interest in the outcome of the civil action.

8 Here, he asserts that if Mason admitted retaliating against him in his whistleblower 

action, she would be admitting a simple misdemeanor.
11

same subject matter against the very optometrists whose licensure 

it was now tasked with reviewing, the court found potential bias 

based on prejudgment of the facts. Id. at 578. The court also 

found that that any action taken by the Board to suspend or revoke 

licensure could redound to the personal financial benefit of the 

Board members in that their decision could result in elimination of a 

large portion of practicing optometrists in the state. Id. In affirming 

the District Court, the Supreme Court only relied on the potential for 

pecuniary interest in the outcome of the administrative proceeding, 

although it recognized both avenues of potential bias. Id. at 578-

79.

The matter presently at issue before the Board of Regents 

differs in two regards to the facts at issue in Gibson. In Gibson, the 

Board of Optometry previously initiated suit against the plaintiffs

alleging professional violations substantially similar to those it was 

tasked with administratively reviewing, leading the court to 

conclude there was a possibility that the Board had already

concluded the optometrists were engaged in illegal practice. Id.

Neither President Mason nor the University sued Dr. Juweid prior to 

resolution of the institutional disciplinary charges filed against him. 

Rather, Dr. Juwied initiated suit against President Mason alleging 

violations of the Iowa Whistleblower Act and his constitutional rights 

while disciplinary proceedings were pending. . . . While the two 

complaints may have stemmed from Dr. Juweid’s employment 

relationship with the University, the issues and allegations are not 

so substantially similar as to give rise to an inference of bias. 

There is nothing to indicate that President Mason prejudged the 

facts at issue in the disciplinary matter simply because Dr. Juweid 

filed suit against her in another forum.

Secondly, Dr. Juweid has presented no evidence indicating 

that President Mason had a personal financial interest in the 

outcome of the disciplinary proceeding. Dr. Juweid argues, without 

further explanation, “[a] favorable decision helped her civil case.

An unfavorable one would have hurt her case. . . . The Supreme 

Court stated, “[i]t is sufficiently clear from our cases that those with 

substantial pecuniary interest in legal proceedings should not 

adjudicate these disputes.” Id. at 579 (citations omitted). While

President Mason may have an interest in the outcome of the civil 

proceeding, she is not the party responsible for adjudicating that 

dispute. Dr. Juweid is free to present whatever arguments he 

deems valuable regarding President Mason’s institutional decision 

and the motivations behind it in his civil litigation, but the mere 

possibility that her decision may be introduced as evidence in 

another forum does not rise to the level of a substantial personal

financial interest in the outcome of the disciplinary matter.

For the purposes of the administrative proceeding President 

Mason is presumed unbiased, and Dr. Juweid carries the burden of 
12

proving otherwise. Schweiker v. McClure, 456 U.S. 188, 195-96 

(1982). The simple fact that two proceedings are pending in two 

different forums is not, in and of itself, enough to establish bias. To 

find otherwise would permit an employee to interfere with 

established University disciplinary procedures simply by filing 

litigation against the decision-maker. Dr. Juweid has not, at this 

time, presented sufficient evidence indicating a likelihood of

success on the issue of bias under either of the factors considered 

in Gibson.

Juweid asserts his best defense in the agency disciplinary proceeding was 

his whistleblower defense, but he was unable to make that argument because

President Mason refused to recuse herself. 9 The record belies this complaint—

Juweid did argue to the faculty panel that his communications with colleagues, 

which were found to have violated section 15.4 of the operations manual, were 

justified due to the lack of action on his concerns about the overuse of imaging. 

The panel considered these contentions:

Dr. Juweid claims that he has whistleblower status (see, e.g., Dr. 

Juweid Post-Hearing Brief at 25). This claim appears to reside in 

his belief that he (Dr. Juweid) exposed incompetence on the part of 

his department chair . . . and that he exposed inappropriate medical 

procedures (in the form of excessive PET-CT scans being 

conducted on a young patient). 

Neither of these factors [is] either mitigating or exculpatory. 

Dr. Juweid violated University and UIHC Policy in a number of ways 

as noted above. He could have pursued his concerns about his 

department chair without violating University and DUIC Policies, 

and he could have pursued his concerns about inappropriate 

medical procedures without violating UUIC policies. Therefore the 

validity or otherwise of his initial concerns does not mitigate any 

sanctions which might be considered.

 

9 He also contended his communications were misunderstood due to cultural 

differences. The panel addressed this claim in its questions to witnesses. 

The panel also addressed Juweid’s claim that he currently suffered from posttraumatic stress syndrome. The panel stated, “Based on the medical reports, we cannot 

find that Dr. Juweid’s behavior during the period in question (February of 2010 to May of 

2011) was caused by post-traumatic stress syndrome.” 
13

Nothing in this record indicates President Mason prejudged the facts of 

Juweid’s appeal following the unanimous recommendation of the faculty panel. 

Moreover, we observe that President Mason’s decision was not the final agency 

action. Rather, the board of regents provided the final ruling, and Juweid makes 

no claim that the board of regents—which was also named as a party in his civil 

action—had a disqualifying conflict of interest. There is no evidence that 

President Mason was ever involved in the investigation, the decision to file the 

complaints against Juweid, litigation strategy, or assumed a personal 

commitment to a particular result. See Botsko, 774 N.W.2d at 851-52 (citing 

Nightlife Partners v. City of Beverly Hills, 133 Cal. Rptr. 2d 234, 246 (Cal. Ct. 

App. 2003)). Juweid has failed to overcome the presumption of honesty and 

integrity of President Mason in ruling on his administrative appeal. See id. at 

849. 

B. Assistant Attorney General. Relying on Nightlife Partners, Juweid 

also claims he was denied due process because Assistant Attorney General 

Carroll represented President Mason in the civil action and argued to her in the 

administrative proceedings. His reliance on Nightlife Partners is misplaced 

because in that case the impermissible conflict arose because the city attorney,

who had insisted the petitioners must submit one type of application to renew 

their adult entertainment permit, also sat next to and advised the hearing officer 

throughout the administrative permit hearing—that is, that the attorney was not 

only an advocate but a de facto decision maker. See 133 Cal. Rptr. 2d at 238-

39. 

The Nightlife Partners court observed:
14

This concern over too close a connection between an 

advocate and the decisionmaker is reflected in various 

administrative procedure acts. Thus, the Model State 

Administrative Procedure Act [(APA)] and various state 

administrative procedure acts, including California’s APA, provide 

for the separation of administrative functions by specifying that an 

employee engaged in prosecuting functions for an agency in a case 

may not, in the same or a factually related case, participate or 

advise in either the decision, or the agency reviews of that decision, 

the only exception being that such employee may participate as a 

witness or counsel in public proceedings.

133 Cal. Rptr. 2d at 244. 

In Botsko, an employer was challenging the fairness of the hearing it 

received before the city’s civil rights commission, which had found the employer 

had discriminated against an employee. 774 N.W.2d at 843. The supreme court 

did not find it troubling that the executive director of the civil rights commission, 

Judith Morrell, made an initial finding of probable cause and later participated as 

advisor in the civil rights commission’s deliberations. Id. at 852. This was 

determined “not sufficient to give rise to a due process violation in the absence of 

a demonstration of actual prejudice.” Id. Nor was the court concerned about 

Morrell’s “participation in the litigation after the agency made its final 

determination. Such post-decision defense of agency action does not inject 

unacceptable risks of bias into the agency determination.”10 Id. at 853. 

 

10 The court was concerned, however, that Morrell “sat at counsel table for the 

[employee] and participated in off-the record conferences with [the employee’s] private 

counsel at the close of testimony.” Botsko, 774 N.W.2d at 853. The court concluded, 

Where it is undisputed that the director of an agency sits at

counsel table with a complainant, confers with that counsel at the close of 

the testimony of witnesses, and does not object when the hearing officer 

suggests that she, along with counsel for the complainant, bears the 

burden of proof, we conclude, as a matter of law, that the director was 

engaged in advocacy on behalf of the complainant. That advocacy is of a 

sufficient nature to preclude her later participation in the adjudicatory 
15

Here Attorney Carroll participated as counsel in public proceedings. See 

Nightlife Partners, 133 Cal. Rptr. 2d at 244. There is nothing in this record 

indicating he acted as an impermissible advisor to President Mason in the 

appellate decision. In Nightlife Partners, the decision of the hearing officer was 

unappealable, see id. at 239, which is not the case here. The decision about 

which Juweid complains is an intermediate administrative appeal. The final 

decision rested with the board of regents. See Botsko, 774 N.W.2d at 853-54 

(noting “the commission may avoid the due process violation by submitting the 

case, on the record previously developed, to a disinterested quorum of current 

commission members”).

The board of regents rejected Juweid’s conflict-of-interest claim 

concerning Attorney Carroll, stating, 

Dr. Juweid further alleges that Assistant Attorney General Carroll’s 

representation of President Mason in the civil suit and the 

University in the disciplinary matter amounted to an impermissible

conflict of interest, requiring President Mason’s recusal. . . . Dr. 

Juweid cites Iowa Rules of Professional Conduct § 32:1.7(a)(1) in 

support of this contention. This rule addresses ethical conflicts of 

interest that arise when the concurrent representation of one client

is directly adverse to the representation of another. The Attorney 

General has the duty to prosecute or defend causes of action for 

which the state or its employees is a party or for which the state’s 

interest requires. [Iowa Code] § 13.2 (2011). This duty applies to 

state administrative hearings. See 1987 WL 119624 (lowa A.G.). 

Dr. Juweid has not demonstrated how Assistant Attorney General 

Carroll’s defense of President Mason in the civil matter adversely 

affected his representation of the University in the disciplinary 

matter. While it is true that the final institutional decision rested 

with President Mason, Dr. Juweid has failed to present evidence

tending to indicate that Assistant Attorney General Carroll’s 

 

process in the case under the due process clauses of the state and 

federal constitutions.

Id.
16

representation improperly influenced her decision or that of the 

Faculty Judicial Panel. 

Upon our de novo review, we conclude Juweid was not denied a fair 

hearing in the administrative proceedings. We therefore affirm.

AFFIRMED.