Dr. Mike Adams
In 1993, Dr. Mike Adams, a self-declared atheist and liberal, began working at the University of North Carolina-Wilmington (UNCW). Initially, he was highly esteemed by both his students and peers. Dr. Adams won many honors, including two-time Professor of the Year, and he outpaced many of his fellow teachers in scholarly publications and awards for outstanding teaching and community service.
During a 1996 teaching exchange in Ecuador, Dr. Adams had an encounter at a prison with death-row inmates that had a life-changing spiritual effect on him. “I really began to see the absurdity of the relativistic worldview, and it lit a fire in me,” he said. After a few years of study and questions, Dr. Adams became a Christian. His new faith also significantly impacted his political views. In his free time, Dr. Adams began publishing online columns that addressed cultural and political issues from a conservative perspective and that critiqued higher education.
Dr. Adams’s co-workers didn’t take too kindly to his new found Christian faith and worldview. They began acting hostile towards him, calling him a liar and mean-spirited, gave him poor evaluations, and even launched a secret investigation against him.
In 2006, Dr. Adams applied for promotion to full professor. In his application, he mentioned that he also wrote online columns. Even with his admirable professional achievements, his promotion was not inevitable. The news came; Dr. Adams was denied his rightly deserved promotion.
He immediately knew what to do:
“Five days after the denial of promotion, I got the letter explaining why I was denied, saying I was deficient in all areas—teaching, research, and service. I was sitting in my office with a service award to my left, UNCW Professor of the Year 1998 in front of me, and UNCW Professor of the Year 2000 to my right. It was very easy for me to pick-up the phone and call Alliance Defending Freedom (ADF) and move forward with my lawsuit.”
After ADF filed a lawsuit on behalf of Dr. Adams against UNCW in 2007, the district court ruled in UNCW’s favor, saying Dr. Adams’s columns in an online publication were not protected by the First Amendment because they were mentioned in his promotion application.
Alliance Defending Freedom appealed the decision to the U.S. Court of Appeals for the Fourth Circuit, which ultimately reversed the decision and sent it back to the district court. In March 2014, after a four-day trial, a federal jury ruled that UNCW violated Dr. Adams’s First Amendment rights.
After the verdict, the court ordered UNCW to promote Dr. Adams to full professor and pay him $50,000 in back pay. UNCW initially appealed the case, but later settled the case, agreeing to drop the appeal, to adopt procedures to protect Dr. Adams from renewed retaliation, and to pay his attorneys’ fees.
When asked how he sees this win having an impact on Christians at other universities, Dr. Adams said, “First of all, it shows that professors can speak out on issues of public concern, and integrate that within their work as professors, and not be punished for their viewpoint. But also, it shows that a conservative can stand up and fight—with ADF—and that there is a chance. David can face Goliath and prevail.”
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Adams v. Trustees of the University of North Carolina-Wilmington
What's at stake
- The right of university professors of any faith or political perspective to express their views without facing retaliation from government officials.
- The right of conservatives and Christians to serve as university professors without experiencing discrimination and retaliation for expressing their views and beliefs.
- The right of conservative and Christian university professors to receive a fair evaluation, without being punished or passed over because they express opinions that university officials do not like.
When Dr. Adams applied for promotion to full professor in 2006, he had no idea he was about to embark upon a constitutional adventure that would last more than seven years. Given his record of accomplishment as a teacher, scholar, and community servant, he had little reason to be concerned about his prospects. But when he was denied promotion, he would gradually expose the depths of animosity towards Christians and conservatives at UNC-Wilmington.
When Dr. Adams arrived at UNCW in 1993, he was a liberal atheist. In the years that followed, he collected an impressive array of accolades for his skills as a teacher, for his output as a scholar, and for his service to the community and university. This included a variety of teaching awards, extremely high student evaluations (sometimes the highest in his department), and a prestigious service award.
In 2000, Dr. Adams became a Christian, and his conversion impacted his political views. In 2002, he began to publish on-line columns in his free time that addressed cultural and political issues from a conservative perspective and that often critiqued higher education.
As a result, his work environment at UNCW changed dramatically. One colleague labeled him a “pathological liar” in the newspaper and filed numerous charges—including “workplace terrorism” accusations—against him without any evidence whatsoever. Others derided him as a “wannabe right wing pundit” and criticized his columns for being too “mean spirited.” Eventually, his supervisor gave him a poor annual evaluation, saying that he was spending too much time on “political matters” and not enough time on research—even though Dr. Adams published nearly twice as many articles as his supervisor. Later, the Chancellor launched a secret investigation of him after an out-of-town anarchist group called the Gender Mutiny Collective complained about his columns.
Even so, when Dr. Adams applied for promotion in 2006, he was confident in his record of achievement. He had out-published all but two of his colleagues, and professors with far fewer than his eleven scholarly publications had previously been promoted. His teaching awards and above-average student evaluations testified to his teaching prowess, and his service record—both on and off campus—was clear.
To UNCW officials, however, this was not enough. They denied Dr. Adams this promotion in a process replete with violated policies, manipulation, deception, and conflicts of interest. They applied a made-up promotion standard that flatly contradicted the faculty handbook. They passed along false information about his academic record, and they deceptively edited documents to turn the faculty vote against Dr. Adams. Later, they openly and repeatedly discussed Dr. Adams’ columns, holding his views against him and even mocking him for them. They allowed the professor who filed false felony charges against him to participate in the promotion process, an outrageous conflict of interest. And after all this, they tried to cover up their illegal actions by giving different explanations for their decision, ultimately claiming that Dr. Adams failed in every area of evaluation.
Shortly after he was denied promotion, Dr. Adams contacted Alliance Defending Freedom, and we filed suit on his behalf in April 2007. Among other things, the lawsuit explained how UNCW officials had retaliated against Dr. Adams because they did not like the conservative opinions he expressed in his columns.
In March 2010, the district court rejected Dr. Adams’ claims and ruled in favor of UNCW. It concluded that the First Amendment did not protect his opinion columns because he had mentioned them in his promotion application. But in 2011, the U.S. Court of Appeals for the Fourth Circuit reversed this decision, in a tremendous victory for academic freedom. Before sending the case back to the district court, it ruled that the First Amendment fully protects these columns and that the UNCW officials could be personally accountable for their actions.
In March 2014, after listening to the evidence from both sides for four days, a federal jury ruled that UNCW had indeed violated Dr. Adams’ First Amendment rights by retaliating against him. It concluded that Dr. Adams’ constitutionally protected speech in his columns and elsewhere was a “substantial factor” in the decision to deny him the promotion and that UNCW had not proven that it would have made the same decision if its officials had not considered his expression.
In April, the district court ruled that UNCW must promote Dr. Adams to full professor and pay him $50,000 in back pay. In May, UNCW appealed the jury verdict and the court’s ruling. In June, the district court ordered UNCW to pay Dr. Adams’ attorneys’ fees. But in July, Dr. Adams’ case concluded with a settlement agreement. In this agreement, UNCW agreed to drop its appeal. It also agreed to promote Dr. Adams to the position of full professor and pay him $50,000 in back pay as the court ordered, to adopt procedures protecting him from renewed retaliation, and to pay $615,000 in attorneys’ fees. As a result, Dr. Adams’ case serves as a powerful reminder that public universities cannot retaliate against those who simply express opinions that some officials do not like.
Our role in this case
Alliance Defending Freedom represented Dr. Adams and defended his right to express his political and religious opinions without facing unconstitutional retaliation from university officials.