The First Circuit Court of Appeals has upheld the decision of Dartmouth College to deny tenure to Professor Amro Farid, who claimed that the denial was based on discrimination due to his religion and national origin. The court's ruling, issued on July 13, 2026, has significant implications for employment discrimination cases in academic institutions.
Farid, a Muslim and Arab-Egyptian, alleged that Dartmouth discriminated against him when it denied his tenure application and retaliated against him for filing a complaint regarding the discrimination. The court's ruling confirms the lower court's summary judgment in favor of Dartmouth, stating that no reasonable jury could find in Farid's favor given the evidence presented.
The case began when Farid joined Dartmouth's Thayer School of Engineering in 2015. He was initially hired as an Associate Professor and expected to be eligible for tenure after three years. However, he agreed to a six-year tenure clock. Farid's tenure application was submitted in the 2020-21 academic year, after receiving negative teaching evaluations and being advised to improve his performance. He claimed that his tenure denial was influenced by discrimination, as he noted disparities in treatment compared to a non-Muslim colleague who received tenure the previous year.
The dispute escalated when Farid filed a complaint with the New Hampshire Commission for Human Rights, alleging discrimination based on his religion and national origin. After the Commission forwarded the complaint to Dartmouth, Farid later withdrew it and filed a lawsuit in federal court, which led to the current appeal. The district court ruled in favor of Dartmouth, prompting Farid's appeal to the First Circuit.
The court's ruling found that Dartmouth had legitimate, non-discriminatory reasons for denying Farid tenure. The court stated, "Even in employment discrimination cases where elusive concepts such as motive or intent are at issue, summary judgment is appropriate if the non-moving party rests merely upon conclusory allegations, improbable inferences, and unsupported speculation." The judges emphasized that the university's tenure decisions rely on subjective judgments and that Farid failed to provide sufficient evidence of pretext, which is necessary to prove discrimination.
In its opinion, the court noted that Farid's qualifications did not match those of Vikrant Vaze, the professor who received tenure the year before. Vaze had better teaching evaluations, more competitive grants, and a stronger publication record. The court highlighted that Farid's claims of disparate treatment were not substantiated, as the evidence showed that Vaze's qualifications were superior.
The ruling has broader implications for similar cases in academic settings. It underscores the importance of documented performance evaluations and the need for clear, objective criteria in tenure decisions. The court's affirmation of the lower court's ruling may deter future claims of discrimination unless substantial evidence is presented.
Looking ahead, Farid's legal options may be limited, as the court's decision is a significant setback for his claims. There is no indication in the ruling that Farid plans to appeal to a higher court, and it remains to be seen if he will pursue any further legal action related to his tenure denial.