Adams v. Trustees of the University of North Carolina–Wilmington

From April 2007 to April 2014
University of North Carolina–Wilmington (Public college or university)
Wilmington, NC, United States

Identity of Speakers

  • Michael Adams

    Michael Adams was an assistant professor of criminology at the University of North Carolina–Wilmington.

Additional Information

  • Incident Nature:
  • Incident Political Orientation:
  • Incident Responses:
  • Incident Status:
  • Did not involve Speech Codes


Michael Adams was an assistant professor of criminology at the University of North Carolina–Wilmington. In 2000, Adams became a Christian, a conversion that transformed both his religious beliefs and his ideological views. Adams became increasingly vocal about various political and social issues, serving as a regular columnist at and appearing on radio and television broadcasts as a commentator. He also published a number of books critical of American higher education, including Welcome to the Ivory Tower of Babel: Confessions of a Conservative College Professor.

In 2004, Adams applied for promotion to the position of full professor. Adams’ application packet included his non-refereed ideological publications as part of his research and scholarship. Ultimately, the senior departmental faculty voted 7–2 to oppose Adams’ promotion.

In April 2007, Adams filed a lawsuit in the U.S. District Court for the Eastern District of North Carolina against the board of trustees and various university administrators, asserting claims for First Amendment retaliation and viewpoint discrimination, denial of equal protection under the Fourteenth Amendment, and religious discrimination under Title VII. Following discovery, the defendants moved for summary judgment. The district court granted the motion and entered judgment in favor of the defendants on all claims.

On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court’s grant of summary judgment as to Adams’ First Amendment claims on the grounds that Adams’ protected speech was not converted into unprotected speech under the First Amendment when it was submitted to the defendants for consideration in connection with Adams’ application for promotion to full professor. However, the court affirmed the district court’s ruling on Adams’ Title VII and Equal Protection claims.

On remand, defendants’ grant of summary judgment was denied. The matter went to trial, and on March 20, 2014, a jury found that UNC Wilmington had retaliated against Adams in violation of his First Amendment rights. On April 8, 2014, the court ordered the defendants to confer the title of full professor upon the plaintiff with pay and benefits backdated to 2007.