others allowing judges to develop aspects of the holding in greater depth. Two cases concerned academic freedom and political correctness. Others involved same-sex marriage and satanic ritual abuse. Academic freedom cases Jeffries v. Harleston The Waters decision had an immediate effect on a case arising from an academic controversy in New York. Following a 1991 speech making assertions that Jews sponsored the slave trade and controlled the media, Leonard Jeffries, chairman of the African-American studies department at the City College of New York (CCNY), was terminated from the chairmanship prior to the end of his three-year term by the City University of New York (CUNY) trustees although he retained his professorship. CUNY administrators claimed they did so for other reasons unrelated to the speech. He sued, was awarded damages, and the Second Circuit upheld the verdict in 1993. After Waters, the university petitioned the Supreme Court for certiorari. The Supreme Court told the Second Circuit to reconsider the case in light of that holding. In 1995, the Second Circuit reversed its original ruling, finding that under Waters the College could have reasonably considered Jeffries' speech disruptive enough to justify adverse action. Judge Joseph M. McLaughlin interpreted Waters to hold, relevant to the Jeffries case, "that the closer the employee's speech reflects on matters of public concern, the greater must be the employer's showing that the speech is likely to be disruptive before it may be punished". The first appellate decision had held that the university had failed to show actual disruption to its operations by the speech. "Waters pulls a crucial support column out from under our earlier Jeffries opinion", McLaughlin wrote, by lowering the requirement to demonstrate only the likelihood. Since the jury had found that a majority of the CUNY trustees voted to end his chairmanship for that reason, his First Amendment rights had not been abridged. McLaughlin also rejected an argument in an amicus brief that Jeffries' academic freedom deserved greater protection than Churchill's, since he was tenured and retained his professorship. Burnham v. Ianni In fall 1991 two students in the History Club at the University of Minnesota Duluth had the idea to photograph professors in the history department with props that represented their specialties for a display near the department offices. Albert Burnham, the club's advisor and a specialist in American military history, wore a coonskin cap while brandishing a .45-caliber military pistol. Ronald Marchese,