Major-Professor Withdrawal Treated as an Academic Judgment: “Careful and Deliberate” Process Satisfies Due Process Without a Disciplinary Hearing

I. Introduction

Lily Barrett v. Diana Williams (11th Cir. June 2, 2026) concerns a neuroscience graduate student’s claim that Florida State University officials violated her procedural due process rights after her faculty advisor (her “major professor”) ended their advising relationship, leaving her unable to continue toward a Ph.D. unless another faculty member agreed to serve as her major professor.

The key parties were:

  • Plaintiff-Appellant: Lily Barrett, former Ph.D. student who ultimately graduated with a master’s degree.
  • Defendants-Appellees: Diana Williams (faculty member and former major professor), Lisa Eckel (program director), and Jennifer Buchanan (named defendant in caption), sued under 42 U.S.C. § 1983 in official and individual capacities.

The core legal issue was what process is constitutionally required when a doctoral student loses their major professor relationship and, as a practical matter, cannot continue in the program—specifically, whether this is a disciplinary deprivation requiring a hearing or an academic judgment requiring only a “careful and deliberate” decisionmaking process.

II. Summary of the Opinion

The Eleventh Circuit affirmed summary judgment for the defendants. Assuming (without deciding) that Barrett had a protected property interest and suffered a deprivation, the court held that she nonetheless received adequate process.

The panel characterized the dispute as academic, not disciplinary: Williams’s decision to stop serving as major professor rested on her assessment of Barrett’s research quality, lab competence, and fitness to progress as a doctoral scientist—an evaluative judgment that, under Supreme Court and circuit precedent, does not trigger the formal hearing requirements associated with student discipline. The court emphasized the University’s repeated warnings, opportunities to improve, and multiple offered avenues for review or discussion—opportunities Barrett often declined to pursue.

Although the district court relied on the idea that Barrett had not sought state-law remedies (citing Doe v. Valencia Coll.), the Eleventh Circuit affirmed on a different ground: the process provided at the University level was constitutionally sufficient.

III. Analysis

A. Precedents Cited

1. Summary judgment and record framing

  • McCreight v. AuburnBank: Provided the de novo standard of review and the requirement that summary judgment is proper where no genuine dispute of material fact exists. The court used this framework to evaluate whether Barrett could show a triable due process deficiency.
  • Beal v. Paramount Pictures Corp.: Reinforced that evidence is viewed in the light most favorable to the nonmovant, but the court need not accept mischaracterizations of the record. This mattered because even disputed allegations (e.g., animal-handling claims) were relevant to the advisor’s evaluative judgment and decisionmaking context.

2. The property-interest starting point

  • Goss v. Lopez and Bd. of Regents of State Colls. v. Roth: Supplied the baseline due process proposition: once the state deprives a person of life, liberty, or property, it must provide due process. The panel assumed arguendo that Barrett had a property interest and a deprivation, allowing it to focus on the sufficiency of process.

3. The academic/disciplinary divide and the “careful and deliberate” standard

  • Bd. of Curators of the Univ. of Missouri v. Horowitz: The cornerstone precedent. The Eleventh Circuit relied on Horowitz’s distinction between disciplinary actions (often requiring notice and an opportunity to respond) and academic judgments (requiring far less formal procedure). Horowitz also supplied the policy rationale: academic decisions are “subjective and evaluative,” often involving cumulative expert judgment not suited to adversarial hearings, and hearings can harm the faculty-student relationship.
  • Haberle v. Univ. of Alabama in Birmingham: Provided the Eleventh Circuit articulation that due process in academic matters is satisfied by a “careful and deliberate” decisionmaking process. The panel treated Barrett’s inability to continue without a major professor as part of the academic progression framework addressed by Haberle.
  • Mahavongsanan v. Hall: Supported the proposition that in academic settings “a hearing may be useless or harmful in finding out the truth concerning scholarship,” reinforcing why the Constitution does not require trial-like procedures for academic evaluations.

4. Binding precedent mechanics and the Fifth-to-Eleventh Circuit bridge

  • Sleeth v. Comm'r and Bonner v. City of Prichard: Explained why pre-October 1, 1981 Fifth Circuit decisions (including Mahavongsanan) are binding in the Eleventh Circuit, strengthening the academic deference line of authority.

5. Speculation, causation, and “not taking advantage” of available process

  • Ave. CLO Fund, Ltd. v. Bank of Am., N.A.: Used to reject Barrett’s theory that defendants must have “tanked” her chances with other professors; conjecture is not a reasonable inference at summary judgment.
  • Arango v. U.S. Dep't of the Treasury: Supported the principle that process is not rendered inadequate merely because the plaintiff declined opportunities to use it or did not get the result she wanted.

6. State-law remedy discussion (background, not the holding)

  • Doe v. Valencia Coll.: The district court treated Valencia as requiring pursuit of an available Florida remedy (state certiorari) following a university disciplinary decision. The Eleventh Circuit noted Barrett’s criticism of Valencia but expressly avoided the question, affirming instead on the ground that she received adequate process internally.

B. Legal Reasoning

  1. Framing the deprivation as academic. The court treated the advisor relationship and Barrett’s progress toward a Ph.D. as an academic evaluation, not a disciplinary sanction. Even though the factual backdrop included alleged misconduct (interpersonal issues, lab protocol concerns, animal-handling reports), Williams’s decision was cast as an assessment that Barrett did not meet doctoral-level standards—analogized to “a failing grade” rather than “punishment.”
  2. Applying the academic due process standard. Under Horowitz and Haberle v. Univ. of Alabama in Birmingham, the Constitution requires only a “careful and deliberate” decisionmaking process for academic judgments, not a formal evidentiary hearing.
  3. Finding notice and opportunity were provided. The court emphasized months of escalating concerns, repeated conversations, warnings (including that further issues could end the advising relationship), and the presentation of options (find a new lab; leave with a master’s; or attempt a constrained path with supervision and altered research direction).
  4. Opportunities for review were offered, even if declined. Barrett declined an “important” meeting with Williams, did not pursue a meeting with her supervisory committee despite the program director’s offer, and did not escalate through the “chain of command” suggested by the graduate ombudsman (department chair/associate deans). The court treated these as meaningful procedural opportunities that existed, even if Barrett chose not to use them.
  5. Written reconsideration was considered. Barrett did submit a 31-page request for reconsideration; Williams testified it received “ample consideration.” The court held that a decisionmaker’s refusal to change course is not evidence of a lack of consideration.
  6. No hearing required because this was not discipline. Barrett argued she deserved a hearing because disputed factual claims existed. The court rejected this as a misstatement of the doctrine: the trigger is whether the action is discipline for violating conduct rules (often suspension/expulsion), not whether some underlying facts are contestable.

C. Impact

Although designated “NOT FOR PUBLICATION” (and thus not intended as precedential in the same way as published opinions), the decision has clear practical guidance for disputes at the boundary between program progression and alleged misconduct:

  • Advisor withdrawal and program progression are likely “academic.” When a faculty member ends an advising relationship based on evaluative judgments about research quality, technique, and professional readiness, courts in the Eleventh Circuit are likely to treat it as an academic matter—even if it is influenced by reports of problematic conduct.
  • Process can be satisfied through iterative, informal academic channels. Repeated warnings, meetings, options for remediation, committee review opportunities, and written reconsideration can collectively satisfy “careful and deliberate” process without any trial-type hearing.
  • Declining offered procedures weakens due process claims. A student who bypasses internal avenues (advisor meeting, committee meeting, chair/dean escalation) may struggle to show the institution denied due process, as opposed to the student electing not to use it.
  • Speculation about sabotage is insufficient. The court’s reliance on Ave. CLO Fund, Ltd. v. Bank of Am., N.A. signals that conjectural theories about behind-the-scenes “badmouthing” will not defeat summary judgment absent concrete evidence.
  • Valencia remains in the background. Because the panel affirmed on adequacy of internal process, it did not resolve debates about Doe v. Valencia Coll. and the role of state-law remedies. Litigants should expect defendants to continue raising Valencia-based arguments, but this case shows courts may avoid the issue when internal process is sufficient on its own.

IV. Complex Concepts Simplified

Procedural due process
The constitutional requirement that the government provide fair procedures before taking away certain protected interests (like some property or liberty interests).
Property interest (in education)
Not every expectation is a protected property right. Here, the court assumed one existed without deciding it, and focused instead on whether the procedures were enough.
Academic vs. disciplinary action
Disciplinary actions address rule violations and order (often suspension/expulsion) and typically require notice and some opportunity to respond. Academic actions assess performance and fitness to progress; they receive judicial deference and require less formal process.
“Careful and deliberate” decisionmaking
A flexible standard for academic decisions: the institution must genuinely evaluate and consider the matter, but it need not hold a formal hearing with witnesses and cross-examination.
Summary judgment
A procedural stage where the court decides whether a trial is necessary. If no reasonable jury could find for the nonmoving party on the evidence, the moving party wins as a matter of law.
42 U.S.C. § 1983
A statute allowing suits against state actors for constitutional violations. It does not create rights itself; it provides a vehicle to enforce federal rights (like due process).

V. Conclusion

The Eleventh Circuit’s decision underscores a durable principle in education law: when a university decision is fundamentally an academic evaluation, due process is satisfied by a careful and deliberate process, not a formal disciplinary hearing. Here, the court found adequate process in repeated warnings, opportunities to respond, reconsideration review, and available internal channels (committee and administrative escalation)—even though the student did not pursue all of them. The opinion thus reinforces institutional discretion in graduate academic judgments, particularly where the disputed action is an advisor’s withdrawal grounded in evaluative concerns about a student’s readiness to complete a doctoral degree.